Subject: File Number S7-15-10

October 22, 2010

I am opposed to capping the ongoing sales charges as well as creating a new share class.

You cannot legislate mutual fund returns nor can you guarantee a lower fund expense will generate a higher return.

You do a disserve to investors and financial advisors when you force investors to buy "A" shares funds and pay an up front sales charge and then require them to hold on to underperforming mutual fund under the pretense you know what`s best for them financially.

The good old days of buy and hold forever are no more. The market today is too volatile and swings are too dramatic to bury your head in the sand and hold and hope for the best. Furthermore, an investor should not make an investment decision solely on the expense of the fund itself. This is very misleading. If we made investments based on expenses only, the best investments would be CDs.

Investors should be cleary informed of expenses but rules should not be put in place to legislate investor investment decisions.

Investors should build portfolios based on "net" returns and not fund expenses. After all it is not the expense of the fund that is important, rather the net return.

The vast majority of my clients object to paying load charges, plus they want the flexibility to move out and into other areas of the market as conditions change. Forcing clients to buy "A" shares and then forcing them to stay within the same family of funds thereafter by only allowing exchanges to protect them from paying higher fees elsewhere is not protecting the investor, rather it limits fund competition as the fund company knows they have the investor locked up because the law does not allow them to bail. to get around this, most higher net worth clients set up fee based accounts, so these buy and hold limitations do not apply to them.

"c" share funds allow investors to be somewhat nimble by allowing them the freedom to move in and about the market as conditions change. There is also an incentive for the financial advisor to continue to do their best to service the invesment client because they are getting paid a trail from the fund. By capping the ongoing sales charges you will eliminate the service a fianancial advisor offers to that client. We can not work for free. Consequently, the client will be back to a buy and hold and hope it all works out strategy because there will be no guidance as to investment advice going forward. The other option would be for these small net worth clients to change over to a fee based account, which will cost them more in over all fees in the end. Small investors may not even have enough to qualify for a fee based account to begin with. Bottomline: what you think sounds good and is in the best interst of the investor is just the opposite. Full disclosure is fine but to legislate how a person can or can not invest their savings kills competition and ultimately net returns to the client. Even though you helped the client save on fees, you run the risk of driving their portfolio in the ground. You should focus more on net returns and let competition dictate the end result.

Furthermore, creating a new share class to allow for retail pricing will be a disaster for the investor. Again investors or advisors don`t make decisions on costs alone, it is net return that is most important. Give us all a level playing field so we can make informed decisions. You will create an unfair pricing advantage to larger firms with the new proposed share class and a lower fee schedule does not necessarily equate to more competent or quality of service by the financial advisor or their investment firm.

Full disclosure is fine, but allow the investor to do what is in their best interest in managing their investments to meet their financial goals. The investor is the loser when you dictate how they can and cannot manage their own investments.

Cregg Miyat
Financial Advisor
Multifinancial Securities