Subject: File No.
From: William H Diersen
Affiliation: NAIFA

October 27, 2010

This would be accomplished by allowing mutual funds to establish new share classes that would be issued at net asset value, without fund managers setting any sales commissions or sales charges. Instead, individual broker-dealers would be able to set their own commission and sales charge amounts that would be based on the level of services they provide, and these fees would be charged directly to the investor.
As broker dealers slash their fees in an effort to gain market share, it will no longer be financially feasible for registered reps to continue to provide the level of individualized advice and services currently offered. Investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice, while middle market investors will be deprived of the guidance they need and deserve.

(Attached File #1: s71510-476.pdf)