Subject: File No. S7-15-10
From: William E. Bulmer, CFP

September 26, 2010

This proposal will actually have the opposite effect from what is intended, mainly to help the consumer.

Consumers who chose to use advisers will continue to have to pay an asset management based fee for those services. Currently those fees are recognized as a reduction in the performance of the underlying mutual funds, and in effect, are therefore tax deductible. If the consumer now has to pay that same fee on a direct basis, most will not be able to obtain any tax benefit, thereby increasing the net cost to the consumer from 30-50%.

What makes much more sense is to fully disclose all fees to the consumer so that they can make informed choices as to what options are best for their personal situation. This is how a capitalist society should work, and it is a fair and reasonable approach that satisfies all the parties involved.