Subject: File No.
From: Tony W Pulley
Affiliation: CLU, ChFC, President of Investment Center at Crossroads Bank

October 28, 2010

I am the President of a community bank investment division for retail accounts. We are in rural Indiana. Most of our clients are middle class America. With over 2200 clients, our average account size is just over $60,000 each. But we give them the kind of service that larger clients would obtain through a fee based account by using the current C-share mutual funds. We actually do actively manage these accounts. While we don't use discretionary trading, we do meet with our clients on a regular basis and re-align, re-allocate and revise their portfolios. We have well out performed our peers through this active management. We treat the C-shares as a fee base. As long as we wait 12 months, we can change managers, asset classes, and fund families with no added cost to them. We do disclose all of our costs incurred and justify every move. While I agree with enhanced disclosure and renaming 12b-1 fees for what they are, the C-share style saves our clients a lot of money. Individual holdings of stock or bonds don't get charged a fee, and the on-going sales charge of the C-share is less than a fee based account fee would be. By eliminating or restricting that share class, those clients will either be forced into a more expensive fee account or be under served. If C-shares automatically convert to NAV after 5 years, how will we reallocate or make manager changes without being concerned someone will cry foul for trying to extend our 5 year C-share trail, already a problem with A-shares. No one fund family can provide the best of all asset classes and a managed set of top performing funds can outperform a portfolio of all one fund family. This is not a good thing for the middle class to small account consumer.