Subject: File No. S7-15-10
From: Steven R. Hartman, CLU, ChFC
Affiliation: Steven R. Hartman, CLU, ChFC

October 27, 2010

To whom it may concern: I am a licensed insurance professional & registered representative with 31 years experience.

I support the new SEC rule 12b-2, however, I strongly object to permitting mutual funds to issue a new class of shares at NAV that would allow broker-dealers to set their own sales charge & commission amounts. As broker-dealers lower their sales charges to gain market share it will no longer be financially feasable for people like me to continue to provide the level of individualized advice and ongoing service that I currently provide to our middle and lower market clients.

The middle & lower market investors really need my help and they would be deprived of the guidance and service that they need and deserve. These are the people the SEC are trying to protect the most and I think this change would be a terrible thing for these type of investors. Only the upper-income investors would potentially benefit from this change.

Thank you for your kind attention to this important matter!


Steven R. Hartman

Steven R. Hartman, CLU, ChFC
Financial Services Professional
Agent, New York Life Insurance Company
Registered Representative offering securities through NYLIFE Securities LLC (member FINRA/SIPC)