Subject: File No. S7-15-10
From: Kevin Kleinfelter, CLU, ChFC
Affiliation: Financial Professional

July 21, 2010

For years there has been ongoing debate over 12b1 fees, their intended purpose and current use. As an advisor, I have the ability to provide fee based services or commissioned products. Holders of both these products rely on me for advice and service often clients will need assistance completing IRA distribution forms, will need to sell positions for a major purchase, change beneficiary or registration, etc. It is on a daily basis that I receive such requests for service. Should the 12b1 fees be done away with, there will be no compensation for the services my staff and I provide. Obviously, staff would be reduced and customers would be left to fend for themselves. Over the last 28 years I have fielded thousands of calls from concerned investors relating to market fluctuations, recessions, current events, etc. My time spent "holding their hand" as I remind them of their original objectives and long range goals far exceeds the time invested in making the original investment purchase. Statistics show that those investors without an advisor tend to time the market and have historically bought high during times of market euphoria only to sell during a downturn. The ongoing personally tailored advise of an investment professional is valued by my many clients.