Subject: File No. S7-15-10
From: Andrew C. Karlinski
Affiliation: AK Financial Group

October 13, 2010

I believe that Rule 12b-1 provides fair compensation to financial advisors for providing middle-class Americans with critical support and guidance in planning to achieve important financial goals ranging from retirement, to college funding for children, to caring for aging parents. The retention of 12b-1 fees is an essential way of aligning the interests of the advisor with the interests of their fund shareholder clients. For this reason, preserving 12b-1 fees for the benefit of small investors should be a top priority.

Mr. Andrew C Karlinski
AK Financial Group