Subject: File No.
From: Jamie Imus
Affiliation: Financial Representative, COUNTRY Financial

October 27, 2010

I have been an insurance professional and registered representative for over 3 years, serving Middle-America. These are folks that typically have less than $100k of investible assets. With the proposal to permit mutual funds to issue a new class of shares at NAV and allow B/D's to set their own sales charge and commission schedule, I agree that we will see a "price war" among investment only firms. This may have some of the same effect that we saw with the ability of individuals to begin trading online, instead of through a "stock broker".

While this may also lead to less service and advice for Middle-American clients from firms that rely significantly on revenue from sales charges and commissions, there are firms like mine that are seeking to serve these clients in a holistic environment that does not rely on single product or revenue streams for their profitability. Firms like mine can provide the needed service and advice, beyond what the revenue from sales charges and commissions justify because we have a diversity of revenue from the client across insurance AND investment products and rely on the longevity of the relationship to justify our revenues, instead of a one time sale and the sales charges and commissions that are associated with them.

I find that the current structure of front-loaded sales charges and commissions DOES NOT incentivize registered representatives to provide continued service and optimal advice, other than for the hope of additional purchases of mutual funds. In addition, current rules and the proposed changes do nothing to prevent the type of churning of mutual funds to produce additional sales charges and commissions. The proposed rule may simply lead to lower pricing for the consumer who is caught in this cycle.

While I am a member of NAIFA and they are in opposition to the proposed change, I am writing in support of the change as I believe it will lead to greater transparency to the industry, and bring us closer to providing the value that the Middle-America investor is paying for in their sales charges and commissions.