Subject: File No. S7-15-10
From: Donald Giguere

October 13, 2010

12b-1 fees are a major component of my practice and they allow me to efficiently (and less expensively for the clients) service our clients thoughout our client investment relationship. To curtail or eliminate 12b-1 fees would be detrimental to me and to many smaller investors.
Please do not change the current structure.
Donald Giguere