Subject: File No.
From: David Koll
Affiliation: NAIFA

November 4, 2010

I have been a licensed insurance agent for 36 years, and have been a registered representative for over 32 years. The entire time I have been with Mutual of Omaha. I support new SEC rule 12b-2, 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 amounts. I believe this would hurt the people that need the advice and assistance of advisors the most. Upper-income investors would continue to be served, but middle and lower income investors would not. This would not be financially feasible for registered representatives to continue to provide the individualized and ongoing service that is provided now.

Isnt this the exact opposite of what is trying to be accomplished?

Thank you very much.