To whom it may concern...

I am a registered rep and life insurance agent.I began in this business before 12b1 fees existed.My experience with my clients is that they want choices in how they pay for their investment purchases.Approximately 90% of my mutual fund owning clients buy A shares,9% buy C shares and 1% buy B shares.Years ago they didn't have these choices.A shares cost 8 1/2%, now they cost no more than 5 3/4% upfront with a 25 basis point trailer.

My clients expect me to be compensated for ongoing service and investment reviews.We use a financial security planning process that focuses on their goals and objectives.I believe my clients get good value from this compensation arrangement compared to the annuity business which is primarily a B share business that never converts to A shares except for a handful of companies.

The concept of trailing compensation allows me to build a business that focuses on delivering service to a smaller number of clients.If there were no trailers my business model would have to focus on aquiring new clients and new assets.The unethical salesperson might be tempted to advise more swithching which drives up client costs.The current compensation system aligns client and broker to work together which provides win-win solutions.

The market has been moving to asset based compensation.Not because it is less expensive for the consumer but because the consumer prefers to pay as they receive service.But that marketplace decision is not for everyone.Being able to buy A shares is less expensive.I mostly sell this model but I couldn't stay in business without the 12b1 trailers.Fee based accounts are normally too expensive for account less than $250,000.The A share and the C share are better values in this market.

Making the disclosure more transparent is certainly an option.But please consider the consequences.If you increase the costs involved in more disclosure, they client is the one that pays.The broker dealers are not going to reduce their margins.I use the Fram Oil Filter me now or pay me later explain share classes.

I believe I deserve to be paid for my services.The 12b1 fee has worked well for that purpose.Please don't take that option away.


John Tuttle


John S. Tuttle, CLU, ChFC; P.O. Box 4718, 6314 Fly Rd., Syracuse, NY 13221 (315) 671- 1820. (315)434-9057 / john.tuttle@nmfn * Northwestern Mutual Financial Network is the marketing name for the sales and distribution arm of The Northwestern Mutual Life Insurance Company and its subsidiaries and affiliates. Agent, The Northwestern Mutual Life Insurance Company (Northwestern Mutual), Milwaukee, WI, life insurance, annuities and disability income insurance, R. Paul Dodd, General Agent. Northwestern Long Term Care Insurance Company (NLTC), Milwaukee, WI, long-term care insurance. NLTC is a subsidiary of Northwestern Mutual. Registered Representative, Northwestern Mutual Investment Services, LLC, (NMIS) securities transactions and brokerage services. NMIS is a wholly-owned company of Northwestern Mutual and is a member of the NASD and SIPC. Northwestern Mutual is not a broker-dealer. There may be instances when this agent represents insurance companies in addition to Northwestern Mutual or NLTC. Northwestern Mutual, its subsidiaries and affiliates may review and retain incoming and outgoing electronic mail for this e-mail address for quality assurance and regulatory compliance purposes. Communications via e-mail are not secure or encrypted. They could be observed by a third party. Your transmission of electronic mail to this address represents your consent to two-way communication by Internet e-mail. If you received this in error, please contact the sender and delete the material from any computer on which it exists.