Subject: File Number S7-15-10

October 25, 2010

The 12b-1 fee is often the only form of compensation that I receive from my smaller, lower income, one investment in mutual funds, type client. Because they do not add to their initial mutual fund investment, I receive no additional sales charges on future investments. Eliminating the 12b-1 fee would eliminate any continuing compensation that I receive and would make my on-going advice and service to these clients pro bono. I do not believe it is appropriate to ask financial advisors to serve their smaller clients for free. If you intend to put all small accounts at a disadvantage and make them fend for themselves, then go ahead with this proposal. I think it is ashame to again, pretend to be looking out for the average investor when in fact you are asking advisors to stop serving them and only work with their higher net worth clients. I pride myself in having families as clients. I have been in this industry for twenty years, and I have never refused to give advice to all of my clients EVEN if their only investment was twenty years ago. The 12b-1 fees make that possible. Please consider the unintended consequences of this proposal. Thank you.

Joy Rockwood
Financial Consulant
Raymond James Financial Services