Subject: File No.
From: Jan P Christensen
Affiliation: CLU, ChFC, LUTCF

November 2, 2010

Dear SEC:

I am very much in support of the new 12b2 rules to be enacted. However it would not be wise to allow broker-dealers to create a new asset class for investment at NAV and allow them to charge what they will. It allows too much discretion and will ultimately hurt the small to large investor. They will not receive the level of service they deserve because of it.


Jan P. Christensen