Subject: File No.
From: Todd W. Swanson, CLU, ChFC, CLTC

November 2, 2010

This is in reference to File # S7-15-00
Over the past 34 years, I have worked with middle and lower market investors, helping them with their investment decisions. If the SEC allows another class of shares that would cause competition between broker dealers, this would hurt the middle and lower market investors. Why? Because the 12b-1 fees would be reduced to the point that it would not enable me or any other registered representative to service them properly, for little or no compensation.

The investors in the middle and lower markets only option would be to work with the discount brokerage firms, where there is no personal contact, just a phone conversation. This would cause many people to leave the mutual fund market for non-securities related investments, and would/could have a devastating effect on the mutual fund market altogether.

As an advisor, I ask that "SEC rule 12b-2" be put into effect, so the 25 basis point service fee will enable me and my colleages to properly service our clients, for years to come.

Best Regards,
Todd W. Swanson