Subject: File No. S7-15-10
From: wade c meeks, III
Affiliation: Financial Advisor, MSSB

August 2, 2010

The current trend in asset management is to use the "a" shares bought at "NAV" and wrap a management fee over this asset allocated portfolio. This proposed change will encourage more of this type of business. It will be extremely good for the Broker/Dealers and the Financial Advisors but will be more expensive for the individual investors.
First, the asset management fees and the combined fees inside of the mutual fund add up to more than the fees paid by the individual investor using the "C" share. The asset fees can go as high as 2% or more and then you add in the mutual fund management fee. This part of the business has exploded over the last 10 years. Before this proposed change is enacted it would be worth studying to see which one is really better for the investor.
Second, the average mutual fund holding period for individual investors is under three years. The "C" share fund has given advisors the ability to recommend appropriate changes to portfolio's without the client having to pay up front sales charges.
Third, by encouraging through regulation advisors to us the "a" share fund I believe you will encourage more "churning" of accounts. I do not believe industry wide investors will hold the "a" share funds long enough to realize the lower fees. These savings are only realized after a heavy upfront commission and a seven plus year ownership.
This proposed change will be more costly not less for investors but will give the political types something to cheer.