Subject: File No.
From: Robert D Davey, CFP
Affiliation: Financial Advisor, Northwestern Mutual

October 27, 2010

Hello SEC:
I have been a licensed insurance professional and registered representative for over __ years.

I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.

I object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount.

This will drive advisors away from middle market as large firms compress charges for 'big box' service.

I'd say, beware of unintended consequences.

Thank you.