Subject: File No.
From: Michael D Walker,
Affiliation: PFR Allstate Financial Servives

October 27, 2010

Re: File number S7-15-10
As a personal finacial represenative most of my clients are middle class market investors. I support SEC rule 12b-2 as it helps to continue the 25 basis points fee that insures the investor receives ongoing service and advice. I also support the use of the terms "marketing and service fees" amd "ongoing sales charge" in place of 12b-1 fees since they are understandable by the investor. However, I object to the SEC allowing mutual funds to create a new class of shares at net asset value thus giving broker dealers ability to set their own sales charge commission structure which will ultimately be lowered to the point that it will remove the advisor role forthe smaller and mid-size investiors. Because these two groups now rely on the professionla counsel from their rep's, the proposed change will make self directing the norm and thus most of the smaller and mid size investors will loose the services they need and deserve. And many will go to other non-investment products which will not give the growth potential they need or want. Please do not permit mutual funds to set their sales charges and commissions.