Subject: File Number S7-15-10

October 28, 2010

I've been a licensed insurance professional and registered representative for over 33 years. While I do support the part of the new SWC rule 12b-2 that continues the 25 basis points fee, I disagree with the SEC allowing for mutual funds to issue a new class of shares at net asset value that would allow the broker-dealers to set their own asset charge and commissions.


Jackson P. Calhoun, Jr., CLU