Subject: File Number S7-15-10

October 27, 2010

I have been a register rep for 14 years and I oppose the proposal of issuing mutual funds at NAV and allowing BDs to set the sales charge. This would encourage churning in client's accounts or forcing clients into fee-bases advisory programs, all of which are more expensive that having a standard sales charge written into the prospectus. It will entail itself into an online BD price cutting war to see which firm can be the first to sell stocks for $1 per trade and run themselves out of business, leaving the client without a financial rep. Do not create the appearance of commoditizing the work that FRs do for middle America by price wars among BDs. If so, FRs are smart enough to position annuities and wrap accounts to clients, before proposing NAV mutual funds. Clients will then pay more in the end.

John E. Dill, CFP®, CLU®, ChFC®, AAMS®, CRPS®, CLTC, CAP®
Wealth Management Advisor