Subject: File Number S7-15-10

October 27, 2010

Secretary Murphy,

I have been a registered rep. for 11 years and my experience has been with Blue collar middle American workers. The changes that are being suggested are both Good & Bad. The good being more transparency and less confusing wording versus 12B-1 Fees. The Bad, creation of a new share class? Most people seeking out what to do to invest in there financial future want a Rep that they know and trust. By creating the new share class I believe the larger Dealer/Brokers will create a marketing message that just says cheaper is better. On the flip side only the more sophisticated investors are going to be willing, able, and knowledgeable enough to really understand the value of a continuing fee or trailers and the level of service and expertise this entails. In my opinion the Big get Bigger and the average Joe gets Cookie cutter if the new share class is created.

Respectfully Sam Firman