Subject: File No.
From: Merra Lee Moffitt
Affiliation: Financial Planner/Advisor

October 27, 2010

I have been an advisor for 10 years and a personal investor for 34 years.

The proposed 12-b-1 rule would make it difficult to serve the middle income people who frankly need the advise if they are to ever have enough money to retire.

The disclosure part of the rule is fine, as disclosure generally leads to education in my experience.

The middle-size investment advisor needs access to guidance and already has plenty of no load with no assistance options.