Subject: File No.
From: Arthur B. Ogren, CLU, LUTCF

November 1, 2010

In 1973 I became a licensed insurance agent. In 1975 I became a Registered Representative and so began a professional career that has lasted over 35 years. Much has changed in those years, most of which has been to benefit the public.

I applaud the renaming of 12-b1 fees in the name of clarification and simplicity for the public investors who are interested in being involved with mutual fund investing.

On that same note, I am confounded as to why anyone would then wish to unnecessarily confuse individuals who concentrate on their own careers and family matters with yet another class of mutual funds.

It has been said that this new fund class will cause reps. to direct their concentration toward higher end investors whose funds generate sales commissions. These individuals will then have to manage their own accounts. Some may do well. I dare say most will not. That is what a Registered Rep. is supposed to do, find answers to guide and help take the confusion out of the various mutual funds for the benefit of the investor.

The end result of this confusion is once more a striation of American society. The most advantaged who can afford to pay for management will. The rest will not. Think it through Your intentions may be good but the end result will not reflect that.