From: BAshe29843@aol.com
Sent: Monday, May 03, 2004 2:08 PM
To: rule-comments@sec.gov
Subject: RE: 12b-1 fees (s7-09-04)

Gentlemen:  As a registered representative, I am very much against the 
elimination of 12b-1 fees.  My clients require on-going service and a 12b-1 fee 
is helpful to pay the cost of that ongoing service.

The fee is relatively small, probably averaging about $25 on a $10,000 
investment, and that fee is split between the registered representative and his 
broker dealer.  The typical registered representative has been faced with, over 
the years, increasing expenses for things such as:

  a.. continuing education 
  b.. licensing 
  c.. errors and omissions insurance 
  d.. client tracking systems 
  e.. computer equipment
along with other expenses that face most businesses such as clerical salaries, 
employee benefits, commerial auto insurance, parking fee increases, postage and 
rising rents.  In the face of these rising expenses, most funds have kept their 
12b-1 at the same levels for the past 20 years.

The problems associated with the mutual fund industry have much more to do with 
questionable market timing decisions and excessive fees at the upper management 
levels than they do with the overcompensation of the average registered 
representative who is servicing and assisting his/her clients.  Please allow 
12b-1 fees to continue as a legitimate and modest method of compensating 
continuing service.  Thank you.

Brian Ashe