Subject: File No. S7-15-10
From: Max Brann
Affiliation: Brann Financial Services, LLC

September 15, 2010

Clients that can not meet the required minimum account value to open a managed account have been able to work with an advisor using "C" shares which allows for greater flexibility for the client and some incentive for the advisor. Without a "C" share option advisors can not afford to manage smaller accounts and the client is left to fend for themselves. Altering the 12b-1 fees as proposed will have adverse side affects for the small individual investor.

Mr Max Brann
Investment Advisor Representative
Brann Financial Services, LLC