Subject: File No.
From: Evan C Barrett
Affiliation: NAIFA

October 27, 2010

I have no problem with renaming 12b-1 fees. I agree that the name itself creates confusion. However, the idea of having broker-dealers set the fees lacks any coherent thought as to the remifications. The ripple effect will casue all BDs to slash fees to near zero in order to compete. We all know that investors are hyped into focusing on the wrong numbers. You get what you pay for. Ongoing service will become non-existant, since reps are not being compensated for it. I'm sorry, but no one works for free not in this country. Creating this race to the bottom will ultimately increase the divide between the wealthy and the poor. The wealthy no the importance of service and advice. And they will continue to pay for it. The struggling middle class, because they are told all fees are bad, will attempt to go it alone, and will ultimately suffer in strategy and performance. They will blame Wall St. and the rich, but it is there fault for believing they no have to do practice financial medicine on themselves. And who lend them to believe they could? The politicians that created a fee structure and environment that naturally led advisors to stop giving advice because they were not being paid for that advice.