Subject: File No.
From: John Houillon
Affiliation: Financial Representative

October 27, 2010

The change proposed, allowing broker - dealers to negotiate down the charges currently known as 12b-1 fees, will result in substantial numbers of individual mid market investors with no ongoing service and support services from reps.

The industry has seen too many "go it alone" fund investors making decisions based on emotion, rather than long term strategy and financial fundamentals, when it comes to their inital allocations and the commitment/follow through when times get tough.

For the small expense that 12b-1 fees represent, the majority of fund investors will continue to benefit greatly from the ongoing service and advice from their representative.

Too many investors will "buy high" and "sell low" without the involvement of a rep.

The proposed change will create this detrimental side effect for investors.

The SEC needs to acknowledge the inherent emotional decision making of most investors. If it does, it will acknowledge, then, the essential role of the representative and the true value proposition of the 12b-1 fees.