Subject: File No.
From: Walker L Wellford, III
Affiliation: Life Insurance / Investment Advisor

November 2, 2010

I have been a licensed insurance professional and registered rep. for about 20 years. Current rules aren't the best but are workable. Isupport new SEC rule 12b-2 which gives 25 bp service fee and the SEC's
proposal to use the term "marketing and service fee".

I do not support any new share class at NAV and allowBroker Dealers to set the price. Competition is not only based on price. For all clients to continue recieving good service this would not be a good idea.
I know I speak for many other agents who will not take the time to write.