Subject: File No. S7-15-10
From: Randall Wilbanks
Affiliation: Vice President Wilbanks Securities

August 3, 2010

I opppose this change in 12B-1 fees. No changes are needed to eliminate 12B-1 fees. There are already ways to get out of paying these fees if you want to use fee based advisors. It is just not needed. What you could address, is the laborious rule requiring the 12B-1 fees to be accrued on the books of broker dealers. This is just a huge waste of time to estimate a number that is always wrong and then correct it after the fact. 12B-1 fees vary month to month with the market and should be treated on a cash basis. Thank you very much.