Subject: File No.
From: Joseph E Wirth
Affiliation: Chartered Financial Consultant

October 27, 2010

I am a 24 year veteran selling financial products to the small-town community I serve. I have been following SEC's proposed changes and agree with your changes to the 12-1 fees descriptions.

However, I have a strong objection to the proposal to allow mutual funds to offer a new class of share at net asset value. My objection is this: the client who most needs the service and direction that I provide is the one with the LEAST amount of assets to manage. By switching to an hourly fee structure, I see this market segment becoming an even more under-served area since this investor is the least-likely to pay fees for service. Self-directed accounts should NOT be the plan for this market. The current system of commisions is by far the most logical, fair and practical approach.
Please reconsider the proposal