Subject: File No.
From: Susan Spancers

October 28, 2010

I have been a licensed insurance professional and registered rep for over 20 years now. I believe offering transparency in disclosure documents as set forth in the new SEC rule 12b-2 rule is fine, but I completely disagree that the SEC should approve to issue a new class of shares that would allow BDs to set their own sales charges and commission amount. This will benefit a few high end investors and this will hurt the middle market investor, people who typically need the most help with their investments. Please consider what you are doing and act in the best interests of investors who need assistance the most.