Subject: File No.
From: David B Bianchi
Affiliation: CLU

October 27, 2010

Re: File #S7-15-10

I am a general practitioner working with the middlet class on their fianancial security dealing with life, disability, long term care, retirement and investments. I spend a lot of time with my clients and a lot of energy keeping up with all of the products I represent. During my 36 years of proving financial services I've always calculated that I lose money on the investment side, but I provide as a service.

I'm all in favor of full disclosure and clarity as it relates to fees, but I am not in favor of a mismatch of fees. That will only stand to confuse the clients I work with and not really offer them any better service. Please move with caution on this proposal.

David B Bianchi