Subject: File No.
From: Daniel J Chambers
Affiliation: President of NAIFA Kankakee Valley Association

October 27, 2010

My clients are almost exclusive middle-class America and I have been in the insurance business for 30 years and security licensed for almost 10 years. I will be forced to give up my security license if the new class of shares are sold at NAV (net asset value). It sounds like a good law to lower commissions but there will be a race to the bottom which means that it will no longer be economically viable for me to maintain my license if I can't earn a living. The exact people you are trying to protect will be hurt the most because they will be relying on the internet for advice. Only wealthier clients will be able to afford pay fee-based advisors. So the rich get richer and the poor get poorer. My clients are not the type to pay for advice. They don't now and they will not likely do it in the future. I do however agree with other provisions of the law to improve transparency of the fees that are being charged by the mutual funds. I hope you take this to heart and realize the true impact of your decisions. I believe these are called unintended consequences. Thanks you so much for your tolerance is listening to my plea.