Subject: File No. S7-15-10
From: William R Harper, Jr.
Affiliation: Managing Director-Investments Wells Fargo Advisors

October 12, 2010

The proposed cap on 12b-1 fees will incentivize advisors towards the sale of "A" shares rather than "C" shares. With "C" shares the client's financial interests are aligned with the advisor: the advisors receives greater compensation if the client is satisfied and the fund is held for a longer time period, less if held for a shorter period. Economic theory tells us that, on the whole, people do what they are incentivized to do. With "C" shares the advisor is incentivized to give good advice. With "A" shares the advisor is incentivized to make the sale. Continuing 'to allow for higher payments to advisors on "C" share sales where the investment is held for an extended time period is in the interests of both clients and advisors who provide good investment advice .

Bill Harper