Subject: File No.
From: William A. Hume
Affiliation: Registered Representative, State Farm VP Management Corp

October 27, 2010

I have been a licensed insurance agent for 32 years and a registered representative for 6 years.

While supporting the new SEC rule 12b-2 I am troubled by the issue of allowing new share classes to be sold at net asset value allowing broker/dealers to set their own sales charges and commission levels. Competition between broker dealers on price and cost, while attractive sounding, will end with the public being underserved due to a lack of access to advice and servicing for the middle and lower ends of the marketplace. Big money accounts will always be served but the rest of the marketplace will suffer as broker dealers compete and we end up with the lowest common denominator. In order for me to continue servicing my clientele, I need to be adequate compensated. If I am not there to help my small to medium size clients, they will be forced to self direct their programs with a poor result likely. The very people the SEC is trying to serve and protect is the very market that will be most impacted negatively by this action. I vote yes to 12b-2 fees and no to the new classes of securities.