Subject: File No. S7-15-10
From: John Rice
Affiliation: investor

October 12, 2010

According to a recent Wall Street Journal article, last year investors paid more than $9.5 billion in 12b-1 fees, which is kind of a lot. These fees are meant to boost sales of funds, which is kind of like asking current car owners to pay an annual fee so that dealers can sell more cars to other people.

The insidious thing (we think) about 12b-1 fees is that they tend to go on in perpetuity. If you invested in a fund in 1980 and never transacted again, you might still be paying 12b-1 fees.

12b-1 fees should be abolished.