Subject: File No. S7-15-10
From: Roger S Green

November 4, 2010

I have been helping middle america with their financial decisions and investing since 1987. I am 42, my wife and I run our small business together and have 6 children and I have had a weekly radio program in the atlanta area since 1998. I am an independent(have been listed in top 100 in the country in Barrons and Registered Rep magazine several times in last five years, in2009 I was listed on cover research mag as one of five advisors placed in the advisor hall of fame, and we won Gwinnett (over 700,000 people) counties chamber of commerce small business award for our size business in 2008), a CFP and have a Masters in Financial services a salaried staff of ten. I help over 800 clients with $2,500 to 100k without any additional charge other than the 1% a year 12b-1 fee i recieve. we fully disclose the fee it is pretax and less than our normal fee of 1.5% to one million(50% higher) we only allow small clients to use the C shares at this reduced cost for our services. We recieve no other compensation for helping these middle class clients. if the rule is changed to cap the fee of 12B-1 i will no longer be able to charge so little (as no billing is required) our competitors charge over 2x as much and have much higher minumums. many will go unserved in the future and costs will rise for sure for these people trying to access good quality advise at a resonable fee. check with the ADV of advisors and see for yourself how high the fees and minimums are at below or around the 10k to 250k levels. THERE IS NO OTHER WAY that is less expensive for these middle american youth and working class people to get services of a financial professional like myself. respectfully your Roger S Green MSFS CFP CHFC AEP please call if you want to discuss 770-931-1414