Subject: File No. S7-15-10
From: Kenneth Powell
Affiliation: none

October 19, 2010

I think that you should look at 12b-1 fees carefully. I am not opposed to paying people for their work, but I am not sure that this is what occurs with 12b-1 fees. The argument is that this pays the broker for his sales amongst other things, but it is an ongoing charge long after the sale. Advertising expenses should ocme out of the profits like at any other company. Force the fund companies back to loads on sales instead. This is up front and very clear to all. Funds like to argue that these fees scare away customers but in the name of transparency, doesn't this make the most sense? THose that do the best job of controlling costs will benefit the most. Competition over clearly outlined costs will best serve the public good and the fund companies for that matter, whether they agree or not.

Thanks for your time.