Subject: File No.
From: Jeffrey L. Allison, ChFC, CLU

November 1, 2010

Re File Number S7-15-10........I am a licensed insurance professional and registered representative for 32 years........while I support the new SEC rule 12b-2 for the improved transparency it will foster, I very strongly objest to the SEC allowing mutual funds to issue new share class at NAV and allowing broker-dealers to set their own sales charge/ commission percentages to that share class ....while attempting to encourage competition amongst broker-dealers based on price may sound like a consumer oriented idea, it is in fact the opposite.... upper income/ upper asset amount investors will be able to pay for investment advise through either fee only planning or by use of assets-under-management arrangements, middle and lower asset investors will simply find broker-dealers providing less and less levels of advise/ services to compensate the B.D.'s for the smaller and smaller fees that the competition "to the bottom" will most likely breed .....please stop the 12b-2 aspect of the regulation so that the small/ middle sized investor does not get squeezed out of the paradigm.