Subject: File No. S7-15-10
From: SARAH E STRATTON
Affiliation: CFP®, CIMA®

July 30, 2010

As a CFP®, CIMA® designee, I disclose 12b1 fees to my clients. I find that the trail of fees is much less than the wrap fees that are charged in the industry. I feel that the public should have a choice in how they pay for an advisor services, and believe in transparency. However,
sometimes the changes that are made by the SEC to benefit the public in theory look great but in practice, end up more confusing/overwhelming with minimal benefit in the end.