Subject: File No. S7-15-10
From: Glenn Goldman
Affiliation: Goldman Lancaster, Inc.

October 27, 2010

To Whom it May Concern,

As a FINRA registered financial advisor with over two decades of experience serving middle class and mass affluent clients, I have strong concerns about elements of the new SEC rule 12b-2. While I support the continuance of the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SEC's proposed use of the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees" to improve transparency in disclosure documents, I have serious misgivings about the notion of permitting mutual funds to issue a new class of shares at net asset value and charging broker-dealers with the responsibility of setting their own sales charge and commission amounts, and thereby competing by offering lower prices than their next competitor and being forced to make promises related to service which they will be unable to keep. It is also quite concerning, given the well-told events in mortgage origination markets over the last decade, to abandon the standardized pricing that has been in place for decades, and open up incentives for brokers to charge "whatever an individual will pay" based on that person's lack of inquisitiveness or sophistication. It is known by all interested in this topic that investing is not simple and not a one-time decision like buying typical consumer products, and that the vast majority of consumers benefit from competent and concerned advice. Those with only a modest amount to invest are already hamstrung in this regard, and without a viable means of compensating advisors for taking them on, they will be neglected even more. While this appears from my vantage point to be an unintended consequence, it will be a stark one just the same.


Glenn Goldman
Goldman Lancaster, Inc.
330 Golden Shore, Suite 260
Long Beach, CA 90802