Subject: File No. S7-15-10
From:Richard Hellmold

October 13, 2010

12b-1 fees allow me to service smaller accounts and smaller investors. Without a C share class, I would not not be compensated for these smaller accounts and investors. I would probably not assist these clients at all. Removing this form of compensation would force these clients to rely on the large wire houses and mutual fund houses that provide generic investment advice that might not be suitable to the smaller client`s situation.