Subject: File No. S7-15-10

October 20, 2010

There has been much talk about the cost of 12b-1 fees over the 21 years I have been working in this industry.

When I first did business, I found it difficult to charge the 8.5% A share charge, indicative of the old days, that was quite common back then. Until, I discovered upon my annual visitis that my clients - with the choice of using no load or load funds, and having opted no loads - had done nothing! I started to understand the value of a sales charge: helping to pay for my services to assist some clients in their attainment of their goals!

As years went along, the "12b-1 trails" I received reminded me of my commitment to the clients I had served in the past, provided me a small compensation for offering ongoing service, and allowed me to continue to serve the `smaller accounts` that I so dearly wanted to help!

Well,over the years I have had opportunity to work with only larger accounts, with folks used to paying for fees and services, and frankly I would rather keep helping the smaller account folks! They need the help MORE than ever! No, I make less for each client, but satisfaction is high, and clients get HELP that they could not/would not pay for otherwise. I attribute this to the trail fee (12b-1s) that all my clients are aware of, and they appreciate knowing how and what fees are used for distribution, etc.

I feel strongly MORE folks will be served LESS by negative changes proposed to 12b-1 fees. There are a lot of scary happenings in our financial world today, and this is not high on the list. I urge you `get real`, and leave the 12b-1 fees as a reasonable expense that is doing something for serving millions of account holders.

Thank you!