Subject: File No. S7-15-10

October 20, 2010

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 is a top priority.

Without 12b-1 fees, we will have to re-evaluate our practice of providing investment advice and services to middle american clients like we did in 2003, which resulted in the termination of client relationships that generated less than $ 1,000 in fees per annum.

Frederick Brown
Registered Investment Advisor