Subject: File Number S7-15-10

October 27, 2010

Dear Sir,

I am a insurance agent and registered representative doing business in South Carolina since 1988. I like parts of the new rule 12b-2, but I don't like the part of the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount. I think middle America suffers with competitive pricing when sales charges are reduced. The SEC will make it so we can only work with upper markets and the lower and middle markets will not get the service and guidance that they have had in the past.
Michael Riffenburg