Subject: File No. S7-15-10
From: Mel Hertz
Affiliation: Derand Capital Management Group

September 15, 2010

The 12b-1 fees that are paid to me by my clients (from the mutual funds that they own) allow them to not pay commissions up front, so that all of their money is working for them from day one. This can be important in an escalating market. These fees also assure my clients that I will be here working on their behalf long after the purchase of the investment, rather than me being paid up front and then disapearing or ignoring the service work that has to be done over the years.

Most of my cients have a braod range of investments with us and the funds that are sold with 12b_1 fees are done to fulfill an asset class that we do not have available in a managed account or for a small speacial titled account.

Please do not eliminate the current 12b_1 fees on "c" shares. They serve my clients well and fairly.

mel hertz
Derand Capital Management Group