Subject: File No. S7-15-10
From: Vivek Kaul
Affiliation: CFP

September 17, 2010

The proposal to cap 12b 1 fees will have an enormous negative impact on services that clients receive from their Financial Advisor. Today, it is in an advisor's best interest to continue to service a client on a consistent and frequent basis because of ongoing 12b 1 fee compensation. If the structure of those fees is changed, an advisor's focus will shift from service and doing financial planning, to generating new compensation (just like the old days of churning).

Also, whatever happened to free markets? People that do not like 12b 1 fees can always call 1-800-Vanguard or another shop that does not have 12b 1 fees.

One more point - these proposals will make it even harder for new recruits to have an enduring career in the industry at a time when financial markets have been struggling for quite sometime.