Subject: File No. S7-15-10
From: Marty Berger, CLU
Affiliation: Berger Benefit Connections

October 27, 2010

As a NAIFA member I believe you have made some progrees on the reform and the name change of 12b-1 to reflect marketing and distribution costs is fair. Clients understand there is no free lunch and deserve clear descriptions of expenses. The fact that there is no free lunch means one other provision is really counter-productive though. The propsal to allow funds to offer at net asset value while the broker-dealer sets their own cost recovery on top of that, will do great harm to the small investor, mainly Middle America. The small investor cannot either afford the fees charged by fee based advisors or they would be such a huge percentage of their investable assets they would be nonsensical. The middle market is difficult to serve on a cost effective basis now, this change would make this considerably more difficult. Class A pricing is still a very logical way to deal with this, a small investor can get the benefits of an advisor for a small commission and the large investor can benefit from the break point - volume discounts available.

-- Marty Berger, CLU
Berger Benefit Connections
14858 West Ridge Lane, Ste 10
Dubuque, IA 52003