Subject: File No. S7-15-10
From: Gary Duell
Affiliation: ChFC

July 23, 2010

12b-1 is an antiquated gift to Wall Street, originally intended to help funds recover from the crash of 1929, by allowing fund managers to use a portion of the fund's assets for marketing purposes. 12b-1 outlived its usefulness 50 years ago and amounts to little more than yet another means for extorting dollars from the average investor and avoiding transparency in the process.
It is way past time to get rid of 12b-1. Nor should it be replaced with any "relief" from market competition.