Subject: File No. S7-15-10

October 19, 2010

Over the last 24 years I have been in business, I have delivered service to clients with and without 12b1 service fees. When we did not have ongoing fees we were always having to add new clients in a effort to have a profitable business. With the addition of 12b1 service fees, it allowed us to better manage our business and limit the number of clients we serve and do so in a more complete financial planning process. The clients are better served because of these fees and I believe it would be a diservice to the people to abolish them.
Kurt Whitesell
Whitesell Financial Group, LLP.