From: David O'Block [advice@davidoblock.com]
Sent: Thursday, May 06, 2004 12:39 PM
To: rule-comments@sec.gov
Subject: S7-09-04

Proposed elimination of 12b-1 fees.

Dear rules committee:

It has come to a point where regulation, intended for the benefit of the 
consumer, actually limits the consumers choices, services and investment 
performance.

"Do-it-yourselfers" have the ability to construct and manage their own 
portfolios of individual stocks, SPDR's and "no-load" funds.  Just as someone 
that wants to build a house for themselves can act as their own general 
contractor, or actually do all of the work themselves.  A relatively small 
percentage of Americans choose to do either investing or home construction all 
by themselves.

Convenience, service, good advice and the great probability that the result 
will be superior with a professional involved makes sense for most people, who 
are willing to pay a small amount in order to reap the benefits of that 
professional help.

If you want to protect the consumers from the "bad guys" in the financial 
services industry (and there are some), find those "bad guys" that are looking 
for a quick buck at the expense of others.  They are NOT the kind of 
investment professional, like me, that prefers to use investments such as "C" 
share mutual funds often.  C shares offer my clients freedom to move their 
money thanks to a short (12 month) CDSC period.  My compensation, through 
trails, is directly tied to the performance of their funds, so my clients and 
I share the goal of having their money grow.  If I do not provide good 
service, they are not penalized if they choose to "fire" me and take their 
money elsewhere, as they would if they had recently paid an up-front sales 
charge.  

I am able to charge a fee through the RIA system, but I don't do so because 
the average fees for a C share (between 100 and 200 basis points) is cheaper 
for the client than if I worked on a fee basis (fund expenses between 50 and 
100 basis points AND a fee between 100 and 200 points...IF your account is big 
enough to qualify).  It will cost my clients more if you force me to work in 
this manner, and the fees would not be spread daily over the year as they are 
with 12b-1 fees.

The "bad guys" in the investment world are looking for a quick up-front 
commission.  They are not interested in building their practice over a long 
time and making a living based on the service and results of their work, as I 
do.


David O'Block, CFP, RFC 
The Equity Advisor Group, Inc. 
One Monroeville Center Suite 825 Monroeville, PA 15146 
Phone: 412-856-4500 Fax: 412-856-3054 New Email: advice@davidoblock.com 
Securities and Advisory Services offered through Mutual Service Corporation, a 
Registered Investment Advisor.  Member NASD/SIPC