Subject: File Number S7-15-10

October 22, 2010

Dear Ms. Murphy,

I understand that the SEC is receiving comment letters from representatives and others in the financial services area in regards to changes of 12b-1 rules. I would ask that you would consider the true needs of clients in regards to today`s investment landscape. Clients are beginning to have to make decisions year-in, year-out, as to the future of their financial resources. Many of those are people cannot afford "fee" brokerage accounts, which give them better and more extensive resources when deciding how to best handle their investments. The cost of many of many of those programs is very prohibitive to clients whose asset base is smaller.

"C" share mutual funds gives clients an avenue in which they can invest, receive ongoing financial services help, and still afford the services provided. It also gives them a choice of flexibility in what to do with their investments if they need to make substantial changes. If they are only provided with "A" share mutual funds, then they often feel obligated to stay with a mutual fund company, even if it does not match their ongoing needs. When they use "C" shares they have the ability to be more fluid in their investment decisions---without the fear of "losing" a portion of the sales load.

This has become even more important during the last two "bear markets" of the early 2000`s and since 2008. The markets have been all over the place and clients need the ability to move, if necessary, without fear of paying excessive loads. By using "C" shares they get options and assistance from financial professionals.

Thank you for hearing my thoughts.

Many Blessings,

Paul Gaschen, ChFC

Mr. Paul Gaschen
Financial Advisor
Gaschen, Johnston & Associates, LLC