Subject: File No. S7-15-10
From: Jim DeGaetano
Affiliation: First Command

October 13, 2010

I have two sets of clients, those that pay 12b-1 fees and those that are in managed accounts for which no 12b-1 fees are charged. The set of clients for which 12b-1 fees are charged do not have the financial resources as my other set of clients, and therefore, are able to receive advice and service as a result of 12b-1 fees. Should there be no 12b-1 fee paid to a servicing advisor, I will be forced to make the decision to let go of these clients and not provide them any service. The high costs of compliance and the time spent as a fiduciary to these clients for which there is no offset to cover at the very least administrative costs will no doubt result in many middle americans being left out yet again. Nothing in life is free, and that includes good financial advice. The value of sound financial advice keeps people from behaving in a way that adversely affects their retirement picture. At the current moment, I don`t charge these clients a fee, but do receive compensation and have not ventured down that road with this set of clients. However, should 12b-1 fees go away, there is no choice but to charge a fee for the value of coaching middle america to make smart decisions. This is my passion, and I enjoy it everyday, partly because I get to directly affect middle america in a positive way. To me, it is an honorable profession. Although my business would be more profitable if directed at the upper class, this is not the direction I have pursued. I`m asking you to not make that decision for me.

Mr. Jim DeGaetano
Financial Advisor
First Command