Subject: File No. S7-15-10

October 20, 2010

I have been in the securities industry since 1971 and have never had a complaint from any of my many retail clients.

My producer group has taken advantage of Fidelity`s liberal sales charge waiver policies to allow our clients to invest with no "haircuts". By using Fidelity`s Advisor funds in T shares, we have built a great business serving many happy clients. This share class pays a service fee (12-b1) of 50bps. If this proposal is implemented, revenue we have built since 1988 will be cut in half. We won`t be able to help many of our smaller clients. Equity mutual fund investors make poor decisions if left without help. DALBAR has done studies for years on how the average American picks his own funds based on last year`s best performer and buys when markets look "good" and sell when markets look "bad".
This severely reduces their returns. What we get paid to help them make better decisions most likely profits them much more than 1/2 of one percent.

We are trying to move our book to a fee based platform, generally charging this same 50bps. These changes, given the extra effort to move and maintain the accounts, make sense only for larger accounts. Little people will be "orphaned".

Please leave these fees alone. If anything, change their name and dislose them in the prospectus just as they are now.

Thank you for your consideration.

Mr. Drennen Williams
Registered Representative
Royal Alliance Assoc.