Subject: File No.
From: Robert B. Joki, C. L. U
Affiliation: Committee member of FINRA districe # 3 committee Member of N. A. F. I A Member of S. F. P. Member of F. S. I . Owner of Bob Joki C. L. U Assoc..

October 27, 2010

I have been licensed for insurance work, in the State of Washington for almost 42 years, and for securities, for 37 years. I do support the proposed new SEC rule 12b-2. I agree that this does more correctly reflect what this 25 basis point fee is for.

I do strongly object to the idea of the SEC allowing the various Mutual fund familys the right to issue a new class of shares at net asset value, that would allow the broker-dealers to set their own sales charges and commissions. This has happened in the past, in segments of the life insurance business with less than stellar results. The problem in those States that allow for this practice is that if there was "competition" for a piece of business, that a "rebate was offered" and at times, the policy was place with "not the highest of rated carriers"

Competition, based on price and cost, sounds good, but can come at the cost of quality advice and service. What people "buy" is the RR, or the advisor. All one has to do is to look at the general retail markets, and the "discounters" supply next to nothing on service. Investment programs, are usually many, many years in duration, and need reasonable service, to be sure that long term objectives have not changed, or for that matter that changes have occured in the stock market, or with tax code, and the "discounter" is no where to be found to talk about what needs to be done, to meet the current needs, and objectives.

This is a very poor idea, and should not be implemeted. Thank you Robert B. Joki