Subject: File No.
From: Dennis Wells

October 27, 2010

File Number S7-15-10
I have been a licensed insurance professional and registered representative for over 20 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.

However, I do object to the SEC permitting mutual funds to issue a new class of shares at NAV that would allow broker-dealers to set their own sales charge and commission amount. Competition based on price and cost "sounds" good but will come at the expense of needed advice and service for middle and smaller market investors.

As broker-dealers lower their sales charges and fees in an effort to gain market share, it will make it harder and will not be financially feasible for registered representatives to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients. As a result, potentially only upper-income investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice. Investors with smaller fund account balances will be forced to self-direct their accounts if they wish to continue to own mutual funds because their advisors will no longer be able to afford to spend the time to guide and advise them, leaving discount brokerage fund platforms as the only affordable option for middle and lower market investors. Thought it is important that the indivdual investor educate themselves in the investment market, they may find it difficult to do so at a low cost. This also opens the education filed up to potentially unscrupulous people. How is this going to be regulated. Is the information they are receiving accurate?

The people the SEC is trying to protect the most--middle and lower market investors—will be hurt the most, since they will be deprived of the guidance and service they need and deserve.