Subject: File No. S7-15-10
From: Damian P Petta
Affiliation: Advisor Harvestwealth Partners Commonwealth B/D

September 27, 2010

12b 1 fees have been a way for clients to obtain advice and great service from professionals who would otherwise not be able to service their accounts. All of my clients are well aware of the fee and the year and one day hold that allow them to exit the fund if needed or exchange within the family. Life is ever changing. Who knows what will happen to a Fund Manager or even a Fund Family. The C class share gives the client the flexibility they need in this ever changing world.
It also puts the client and advisor on the same side of the table. An A or B share pays the advisor up front where a C class share is a smaller amount on going. This means I am willing to take less now because I am confident my clients will stay with me for a long time. It also gives the client the ability to walk away from me should I not do my job to their satisfaction. They can move knowing they havent paid me 4% up front. In addition, if there is something going wrong with a fund family we can get out with either a small penalty or no penalty after a year and one day.
I take pride in helping my clients achieve their goals and dreams and do my best to protect them from the difficult markets weve experienced. I make all my clients aware of the 12B 1 fee and how it compensates me on going. Many clients are not in the position to have fee based accounts or dont want to give discretion to an advisor.
Limiting the choices clients have is a big mistake. If this type of law goes through my clients will be forced to go fee based or find somewhere else to go. They will have to pay more because all the Wire Houses and Broker Dealers charge an administrative fee on fee based accounts. So they will pay an additional .25% for the switch.
Lets not forget to mention all the advisors who have built their business in this very ethical manner. Any change on existing shares will destroy their business. I hope the people making these decisions understand the consequences of these changes. Clearly disclosure is so important. Clients need and deserve to know what and how they are being charged for services and products, but taking away C class shares takes away choice, increases cost in most cases, and worst of all, will make advisory services unavailable to those who need it most.

Damian Petta