Subject: File No.
From: Kevin D Vaughan
Affiliation: Vice President, Branch Manager

November 1, 2010

I am concerned that investors beginning a savings program and investors with small amounts to invest will be shut out from seeking professional guidance.

The unintended consequence will be people making unsuitable investments because of ignorance, or being sucked in by slick MF advertising pronouncing returns of the past. Most new investors, even after looking into the details, do not truly comprehend the information.

The high expense of MF are hidden in the trading charges not disclosed as the highest ongoing expense of a fund. The 12b-1 fees brokers receive are the smallest cost to the consumer.

If you compare the "all in" expense of any retail class of MF to alternative advisory and portfolio services you will see that MF are the highest cost investment over any 10 year period. The .25% 12-b 1 fee is the smallest portion cost of the MF investment.

As bad as this rule may seem for small broker dealers, it will have a greater negative impact on the consumer you are trying to help. They will be driven to 1-800 serve yourself investing. Investing is becoming more complicated. Risk is tougher for the pedestrian to judge. Don't deprive people of a better future by making advice and service a commodity.