Subject: File No. S7-15-10
From: Robert Schultz

October 17, 2010

12b-1 fees should be opposed because (1) they do not benefit existing shareholders (the owners of the fund), (2) they are insufficiently transparent to mutual fund shareholders, and (3) they hit all shareholders of any fund share class that imposes them, potentially for years after the shareholders make any investment in the fund, even those who don't benefit from the advice that the 12b-1 fees are intended to provide.