Subject: File No. S7-15-10
From: Laurence Menna
Affiliation: President, Menna Capital Management, LLC

October 13, 2010

I think it is important for everyone to understand that many investors remain on the books of advisors because of some type of compensation to the advisor. If 12b-1`s are repealed in their entirety, many clients will lose any advice they are recieving. At my firm, we open all new accounts on an advisory basis. We have chosen to stay away from the commission business as much as possible. 12b-1 fees would not affect our newer accounts, as currently they are credited back to our clients since we already charge an asset management fee. But for many older accounts under the commission based model we rely on 12b-1 fees in order to have some type of compensation so we can service our client. If 12b-1 fees were eliminated we would be forced to terminate these relationships and basically feed them to the sharks. I think the focus of the SEC needs to be on the sharks! More punishment and higher fines for the thieves.

Laurence Menna
Menna Capital Management, LLC