Subject: File No. S7-15-10
From: R Bertram Williams, III
Affiliation: financial advisor associated with Wells Fargo Advisors

August 16, 2010


I am an investment broker with the same firm for 32 years plus, although my firm has had 6 or 7 name changes during my association.

I wanted to comment on the proposed mutual fund sales charge rules I am hearing about.

I make every attempt to do what is right for my client. Unless my client is investing a very significant amount, or already has a very significant amount in a particular mutual fund family, I have exclusively offered "C" shares for the past several years. It has been my experience that even though my client may tell me he is investing for X number of years, he often requests funds back much earlier, or his circumstances change and the investment is not as appropriate for him as it originally was. I cannot rightfully charge a client 4% or 5% or 5.75% up front in an "A" share. I do not think it is the ethical thing to do. He can have all his money go to work for him initially with no out of pocket charges with "C" shares. Then, when he requests redemption in 2 or 3 years he can access his fund balance with no charge.

In my opinion, it is most often the best option for my client it is not the best option for me, his broker.

My suggestion is to limit the trailing 12-B 1 charges in "C" shares to some period of time- maybe 5 or 6 years. Then the client has his flexibility which is all important and in addition, he would not end up paying excessively for the services of his investment counselor.

I welcome your feedback.

Bert Williams