Subject: File Number S7-15-10

October 21, 2010

Your 12b1 fees on C shares may seem inappropriate for million dollar clients, and probably are. But most clients have less than $100,000 invested with us and the C share is what they need. It has the least conflict-of-interest by eliminating `churning` that you have with A shares. If you lower the basis trails to .25 after several years, then the adviser has no (very little) reason to service these small accounts so they will be ignored. And they need the financial advice more than anyone for mortgages, taxes, retirement planning, etc. which we do not get paid for separately.
So go ahead and make the fees more open and obvious, but don`t lower the trails or the small clients will get ignored even more than they are now.

James Startzell