Subject: Changes to Rule 12b-1; File Number S7-15-10

October 28, 2010

Elizabeth M. Murphy, Secretary
Securities and Exchange Commission

I have been a licensed insurance professional and registered representative for over 25 years. I do not support any changes to the existing 12b-1 Rules. I have never had a complaint or comment from any client regarding these fees. In fact, many clients have asked if the modest fees they are charged for my services are adequate. I believe the ultimate effect of the proposed changes will result in many low and middle income clients being priced out of available services.

Thank you for considering my opinion.

David M. Edwards, LUTCF