Subject: File No. S7-15-10
From: Michael T. Day, LUTCF
Affiliation: Registered Representative

October 27, 2010

To whom it may concern,

I am writing to comment on the proposed regs regarding 12b-1 fees.

I have been an insurance professional for 22 years. 12b-1 fees are a necessary and ongoing revenue stream for to provide the best service for my clients. I support the 12b-2 rule which would continue with the 25 basis point fee used to ensure ongoing service to my clients….and I support any changes as to transparency and disclosure. However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value and allow BD's to set their own sales charge and commission amount!! This will drive the fees down to a zero or minimum amount in an effort of gain market share……….and this leaves a great dilemma for advisors in helping their clients. Simply put, I could not afford to give valuable advice to most of my clients! From this, the public is NOT served.

The people the SEC is trying to help the most, will indeed, be hurt the most. Although well intentioned, this change would be a disaster for the middle income consumer of mutual fund products.

Thank you for your consideration of my comments.

Mike Day