Subject: File No. S7-15-10
From: Aaron B. Wilbanks
Affiliation: President and CEO, Wilbanks Securities, Inc.

July 28, 2010

The SEC has now voted in favor of a proposal to limit 12B1 fees in mutual funds to the amount investors would pay if buying A shares. This means that if an A share fund costs 6%, then purchasing a C share that pays a 1% trail would force the fund company to convert the C shaes to A shares after 6 years. After the six years and the conversion to A shares, the fund will pay the broker only 25 bps annually. In essence, this proposal will kill ongoing C share business and force all higher service accounts to the fee side.

The proposal also purports to allow representatives to offer their own sales charges to customers, in effect to attempt to get brokers to discount these charges to clients when selling up-front load funds.

Wilbanks Securities is vehemently opposed to this proposal
as it undermines consumer choice and is another example of
government interference in the market and with absolutely
no justification. Why should consumers be forced to pay a
1% fee if they do not like their account being charged,
they would prefer the C-share alternative and allow the 1%
or 75 bps trail to the rep? Should the SEC be allowed in
effect to force all high service representatives to the fee
based side of our business? We believe in choice and this
completely removes choice both for the investor and the
representative. This is a very bad proposal.

Secondly, the proposal purports to turn representatives into what is qualitatively tantamount to a used car salesmen, negotiating on how much clients will pay. This ruins the professionalism of our industry and will hurt service to clients. It will erode the quality of registered representatives in our business. This is very bad for the public and for our industry, which is already under significant economic duress.

The public is not clamoring for this change. The SEC and Washington is interfering with the market and inappropriately we feel.

We, at Wilbanks Securities, Inc., urge the SEC not to implement this rule.