Subject: File No.
From: Robert G O'Fallon
Affiliation: National Association of Insurance and Financial Advisors

November 2, 2010

Subject: File Number: S7-15-10

I have been an investment professional and registered representative for over 32 years and I support the new SEC rule 12b-2, which would continue the 25 basis points fee that isused to ensure investors recieve ongoing service and advice.

However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker/dealers to set their own sales charge and commission amount.

The idea that competition based on price and cost alone may cause many in my field to be forced to work only with the higher net worth people. This concept would leave the middle and lower class group, who often needs the great advice and direction, without any outlet for that service.