Subject: File No. S7-15-10
From: Ronald J, Duswalt, CFP, ChFC, CLU, MSFS, CFEd

July 30, 2010

My concern becomes when helping a client. If one has the option to use an "A" share vs using a "C" share. The client would end up paying a front load that can be as high as 5.75% and then there is no incentive for the advisor to do reviews on their clients' portfolio. Yes the commission can be lower if they use one family of funds. The problem is that the funds may not be the best in their respective category. The client may receive a discounted commission, but may possibly sacrifice rate of return on the underlying fund. The "C" share gives the client greater fund flexibility. The use of "C" share gives the advisor an ongoing 1.00% fee, which is signfificantly less that the upfront commssion. The big difference is that there is plenty on incentive to help the client achieve their goals by doing periodic reviews. In addition, if the fund they initially picked is underperforming they can change the fund with no fee after one year (in most cases). This becomes an easier decision on a potential fund change than angsting over the fact that I just paid a commission to get into my current fund. It gives the client more flexibility to manage towards their goals. This will encourage the advisor as well as the fund manager to focus on consistent performance. The difference in the ongoing fee of "A" share vs. "C" share is approximately 70-80 basis points more for "C" shares, but the "A" share you pay an upfront commission ranging from 2.50% to as high as 5.75%. I think using this "C" share pricing structure gives the consumer more flexibility in managing their assets. It would be a shame to only give the consumer an upfront commission as the only choice.