Subject: File No. S7-15-10
From: Tedd J. Hoyt
Affiliation: Financial Advisor

September 24, 2010

Dear Sir/Madam:

The proposed legislation to abolish 12b-1 fees is short sighted and will invite confusion and poor investment performance for the average investor, ultimately costing them more in fees.

As an advisor, C shares motivate me to provide ongoing investment advice, support and service to my mutual fund clients. With C shares, when a clients' investment performance goes up or down, so does compensation and as result, each account is viewed on a daily basis and clients are advised accordingly so as to maximize performance. C shares help to offset expenses that include monitoring accounts, quarterly newsletters, ongoing face to face reviews, meals and telephone conversations that consumme time.

Fee-based models for larger accounts as an alternative to C shares are good, but too costly for small accounts. For the smaller client, the C share option is the best full service client-focused advisor model available.

Eliminating 12b-1 fees would force advisors to convert hundreds of thousands of small accounts to fee based models, ultimately costing small investors more.

Suggestion: Modify 12b-1 fees on individual accounts greater than $500,000 and leave them in place for those accounts less than $500K.


Tedd J. Hoyt