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the same each year Because returns and expenses vary over time, your results will bo highor or lower than those shown.

Sales loads do not apply to reinvested mutual fund dividends and other distributions, and the results reflect this fact. However, the results do aot reflect the
application of cther tees that may apply, suzh as ETF commissions, exchange lees, of accounl ma-ntenance fees. Had these fees been considered your costs
would be higher and account values lower. Results also do act ratlect ail the opoo:tunities for waivers or discounts on sales charges on load funds. Trese
waivers or discounts may be based on, for examole, letters of intent, rights of accumulation, reinstatements or NAY transfer piograms If you are enlilled to
them, you should take them into acecunt when estimattig your actual expenses Remember thal selecting a (und involves move than just comparing fund
expenses and fees, You should read a fund's prospectus carefully before investirg to learn about the {und’s invesimert objective, strategies, risks. and the
taxes you may have to psy when you receive a distraution As with any investment. make sure a fund's objectrvas and goals are consistent with your own and
assess how it will impact the d:verssficalion of your portfolia

Brenkpoints: Mutual funds with front-end lozcs or sales charges enable you to reduce (ront-and charges a8 the amaunt of your invesiment increases lo certain
levels called “breakpoints.” While breakpoints vary from fund to fund, based on the investment amount you entered, you may be at of rear a breakpoint. Please
see the Fund Details reper fer additional details or if addstional breakpoints will reduce the front-end sales charge further. For more information on breakpo.rts
please read FINRA’s investor Alert — Mutual Fund Sreakpoints 4 Break Werth Taking

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encouraged to review finsa.org’s publications that oulline a broker's obligalion to deliver breakpoint discounts, including Notice Ie Members 02-85 and FINRA's
online Webcast. “Mutual Funds. Share Classes & Breakpoint Discounts *

We hope you find FINRA’s Fund Analyzer helpful. If you have any questions or ideas about now we can improve this tool, please email us

ita Baviene Promzes 8y: Cancun

Hoan” PRS

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Chart

Redeemed Fund Value

Redeemed Fund Value Over Time After Expenses

Amesicnn Funds American Balances Oppenheimer Maio Street Sinall
Fund® Class A Cap Fund Clees C

600.000

‘$400,000.

$200,000 -

Poser


FEE/DISCOUNT REPORT
RADA Oppenheimer Main Street Small Cap Fund Class C [OSCCX]

Data es of
srinao\s
Load Type
Load Type | ! | Levet toed

Breakpoint Sc!

Oreakpoint schedsles do not apply for Lus fund

$45,589 99)

525,600.00.

$50,009.60 398 859.99,
$100.000.00f S24E 989.05];
$250,009 00. 3a9¢ 999.99|!
i 3509,000.09, $79,968 93] |
' $750,000.00, 7 se08,593 59]!
34 009,000.00, $9,599,959 89]!
; '$10,009,090.00. 524 $99,990 99)
{ ‘525,000 090.00. 599,999 999 999,999,
ROA SSE SS
IROK Atowed i i ‘to

sci we %
ROA Inctuston This fled irictydha in ROA Eareuttions
RCA Alowed Ee

jacross Brokers
feo

+ | Tals tard Us eluded ip ROA esleuletions

3 1 No! Applicable

1 Not Apptieatte

ROA by Relatve:

|
= ROA Calculation: Gorter of ahnres.mutindind hie HAS ec nad dolid invesiad ______ Nat Anoiienlule ns



Annual
Operating
Expenses

Prospoctve
Objective

Momingstar
Category

Momingster
Rating 3-year)

€ Lees than Average of Similar Balanced Mutust Funds: 1.25% (81 Mutvel Funds)
Less thn Average of Similar Wodsralé Adoration Mutual Funds: 1.26% (134
Oe ee :

iLess than A‘pfai'6t Sitar Horotageter 3 Star Rated (year) butuel Funds:
16% (978 unde) om

.¢

Oppenheimer Main Street Small Cap Fund Class C
212%

«tees Bian Average of Similor Smoll Company Mutual Funds: 2.13% (176 Mutual
Fonds)

Create than Avecage of Simo Seal! Blond Mutual Funds: 2.07% (80 Muiuat
> Funda

ole

Poe arti”



Oppenheimer Main Street Small Cap Fund Class C

Redeamod Valve " ProfittLoss Foes & Expenses

$254,409.78 $4,499.78 stanss
a1 : $9,283.24 $264,163.21 514,103.21 $19,096.26
310,054.28 : ‘$271,573.77 ‘$21,573.77 ‘S16.577.06
“512,625.48 $279,171.08 “$29,971.08 $22.414.76
saz “296,960.92 _ $36,980.92 $26.415.76
$16,090.60 + $285,009.25 $45,000.25 $24.58465
“Sirseiae } s303,262.17 $53.262.17 $40,926.11
, | sast,7a5.06 $61,745.56 547 44497
£ ssan.c67 $54,146.20
‘soneaeas .
“see.640.it “wens
$96,121.83 ‘S75.395.61
s107,860.58 " sa2879.97
: $117,871.77 $90,571.46,
. j save.s6303 “si28 163.03 : 596,479.16
5388,742.19 $138,742.19 $106,608 06
2 ~ 's $114,964.40
$129,554.49
$132,304.88
$145,462.33



Aversge Annual — 7.30% 191%
Return: 4 Yeer
Average Annual 12.74% oo
Return: § Yeor
Averege Annuel mo
Return, 19 Year
Average Anau! 12.87%
Return:
‘Since Incoption
Convertible Snore No - Fund does net convert
Class :
Annual Operation 212%
Expenses
| Thi fund dogs not have front-end ssles chergee
: {525,000.00
F [550,000.00
— [Bi00,000.00
hedule Be earn
(Front-End Loe) :|8780:000.c0 [s2s0.000.00
or (Brenkpointa) {5250.00.00 [s500.000.00
{3600.00.00 780,000.00 ‘
{S750.000.00 +.000.000.00 1.5%
|[Ses0,s¢9,099.00

Contingent
Deterred Sales
Charges: (COSC
or Back-End Loed)

Redemption Fee
Schedule

i

i
4
tet
M
1
4

This fund does nat have redemption fees,



From: John W. Gruber, ChFC, CLU, RICP [mail to: johngruber48@yahoo.com]
To: EBSA, E-ORI - EBSA
Subject: Proposed Fiduciary Duty Rule Comment

June 20, 2015

Thomas E. Perez, Secretary
U.S. Department of Labor

200 Constitution Avenue, N.W.
Washington, D.C. 20210

Re: Department of Labor’s Proposed Fiduciary Duty Rule

Dear Secretary Perez:

The BICE section of the proposed regulation requires that financial institutions are required to disclose,
and update at least quarterly, all direct and indirect compensation received with respect to all assets of
all retirement customers of the financial institution and all affiliates for the last 365 days. Institutions
will have to provide the same information with respect to all assets that a retirement customer could
possibly purchase (other than assets not commonly purchased). | ask you, how is it even possible to
identify and then gather and report detailed data on every asset available in our universe of investments
that are suitable for placement in a retirement plan? And to do this same exercise over and over again
on a quarterly basis?

The BICE section of your proposed regulation will be impractical and costly to implement. It will be very
difficult for an advisor and his supervisory firm to comply with the BICE reporting requirements.
Advisors and their supervisory firms will face significantly higher risk of being found non-compliant with
the new regulations and subject to fines and disciplinary action from regulatory authorities. Advisors
and their supervisory firms will necessarily need to pay for these higher compliance costs by charging
individual investors and other clients higher fees for services. The logical consequence of the higher cost
for individual investors will be lower net rates of return, and less capability to accomplish their long-
term goals like educating their children and retiring.

Because compliance with the BICE exemption will be practically impossible and the potential liability
(fines and disciplinary actions) for advisors and their supervisory firms will be high, it is likely that the
vast majority of financial advisors will transition to the fee based model for providing their services
because this type of compensation is considered non-conflicting by the Department of Labor.
Compliance and reporting requirements for advisors compensated with level asset based fees will be far
less burdensome than those required of advisors seeking to work under the BICE exemption. Under the
level asset based fee compensation model, most advisors are compensated a level fee based on the
amount of assets under management.



Purchase et NAV

NAY Purchase if No Ne
Wrap or Fae:
bused Account
Distribution Distibutions cea be autometicaly relrvested (game fund or actos funds in same "Distributions can be setomatcally reinvested (seme tund oF across funds In seme
Reinvestment family). Seles cherges do not epbly family} seles charges do not spely

cpsc

CSC tor $0.01 to $999,999.99)

| COSC for $9 01 to $49,999,999,959,959 99
Saas Repent Chan Be Awe eon
7.0800000% 12 monthe|
COSC Schedule
‘COSC for $1,000,000.00 lo $99,599,$99,590,95
gles sy eee EN
COSC Time ‘Shore age is based upon exact kebiement dale (i.e, # aattiement was on 6/15/2006 .' Share age ts besed upon exnct trade date (4 if trade was on 6/15/2006 then 1
Ceteulation ‘then 1 yor Is 6/18/2007) y | year is @/1S/2007)
ethos } :
DSC Fee CDS calculation uses the towe: | CDSG calculation uses the fower value of either the cunent price per share oF
Gricuistion "orginal pice per share | original price per share
Method
H + Gor eorrection Error correttion
+. Death of one or more of the ae: Geeth of one or more of the sccount holders
Disabiily of one or mere of the Dissblity of one or more of ine account holders
+ Cuistiied distribetion to one or ‘Qualified distribution to ane or more of the account hoksers
waived tor required ammount) | wolved for required amount)

+ Sijstematic wihidraan! plana (1: 4] Divoree of one or mare af the account hotsert

COSC Waivers: x apis ‘ +| Defined contribution pleres

| Teeninelion distributions

Oemininus distribution from 2 defined conindutten pian

on-vested pertleipont batarce distribution from » cefined contribution plan
Loan distribution from @ defined contribution plan

‘Excess contribution distributton trcm @ defined contribution plan

128-1 Fees

Post Agrooment Custer 12b-1 Fee Is
Rate .

Redemption Fees
— ~ Pape 9/1)



tsetnocotogy

Front Load NAV Yes
Purchase Eligitte

fer ROA
Lol

Lolamowed Yes

$28,000.00
LO! Minerauen
; lta purchase mst be at fensl SO 01

LOI Puttuiment

Period

LO‘ Fumtnnent | Grobe Dollore vested fpurehases only)

Calculation =f
\Metnocology

Front Lood NAV
Purchases

Eligible for LOW?

Retrov: live LO!
Allowed

Retroaztve Lot
Period Ee

Sates Charge Waivers
Sen

NAV Repurchase
Allowed

Nol Appiceble

Not Applicable:

Not Appheable

Not Appticable

Pages



Oppenheimer Main Street Smail Cap Fund Class C

lorniagstar Style Box
Vglve Blend Growin

Hey PIN. 2832)

Ff

Morningstar Style BoxTM
Voiue Blond Growth

weurg pyy e6ve7

‘wirw.oppenheimertunds.com

page 7



Repon Genesated en Satonday, lune 20, 2015

einra®” Fund Analyzer Report

FUNDS
Amefican Funds American Balanced Funt® Class A [ABALX}

Oppenheimer Main Street Small Cap Fund Class C {OSCCX}

EXPENSE ANALYSIS

Oppenheimer Main Street Small Cap Fund Cisss C

Teroauoss |sinineas
[Protons [aici
Total Fees | 524,206506

‘Sales Charges 5 3d!

Toll Fees | $7,950,06
coo

Page vet



How is it in the best interest of an individual investor to use a fee based account with average total costs
when a commission based approach can be used that could reasonably be expected to yield
considerably superior results net of all expenses?

Further, | have researched actual performance history published by many highly ranked institutional
investment managers like Morningstar, Blackrock, Goldman Sachs, and others. When the cost of these
investment managers are combined with the average advisor related fees for advice and service, none
of these firms have produced net rates of return over full market cycles that are superior to comparable
commission based mutual fund returns offered by notable companies fike the American Funds,
MainStay Funds, Franklin-Templeton and others. In fact, | find the net rates of return on the fee based
platforms to be considerably inferior to those of highly ranked mutual funds such as those mentioned
here,

Again, how is it in the best interest of individual investors to pay more for their retirement account
advisors and product companies, unless it can be demonstrated that they will experience superior net
rates of return on their investment?

Our industry already has a strong regulatory environment that promotes the best interest of individual
investors with their financial advisors. Are there some bad actors among financial advisors? Of course
there are. These bad actors can be fined, disciplined, and even jailed for their actions.

More can be done to foster the best interest of individual investors and all participants in the retirement
savings arena, but the Department of Labor’s current proposal for fiduciary reform is not the way to
accomplish this. The BICE exemption portion of this proposal is what I’ve focused on here, but | believe
the entire proposal needs to be set aside and an entirely new effort should be undertaken by a joint
committee comprised of a cohort of individua! investors, industry feaders, SEC, FINRA and Department
of Labor representatives.

Submitted by:

John W. Gruber, ChFC, CLU, RICP
Manager

Living With Money LLC

15007 Middle Fairway Dr.

Spring Hill, FL 34609
585-309-0622



Consider that according te a 2011 study by PriceMetrix, in which 15000 advisors and 1 million fee based
accounts were surveyed, the average annual fee for advisory services was 1.47% on accounts with
between $250,000 - $500,000. The advisor fee does not include the cost of investment products held in
the accounts. Assuming a product fee of 0.65%, the total annual cost for an investor using the average
fee based account was 2.12%.

Let’s compare the average fee based account with an account serviced by an advisor who uses a
commission based mutua! fund. Consider the American Balanced Fund (ABALX). This is a popular
commission based mutual fund with a maximum sales charge of 5.75% imposed on purchases below
$25,000. The sales charge is reduced to 2.5% for purchases of $250,000. The total annua! operating
expense of this fund was 0.59% in the most recent operating year, according to the prospectus. An
advisor who is compensated by commissions, who sells this mutual fund to a client as an asset to be
held in a retirement account, will receive all of his compensation for serving this client from the 5.75%
sales charge, and then from the 12b-1 fee, which is included In the 0.59% total annual operating
expense of the mutual fund. There is no additional advisor related compensation from the sale or
service associated with this mutual fund, There are no additional fees paid to the mutual fund company
in this type of account either, but there may be a nominal $10 annual custodlal fee for retirement
accounts. In my own practice as a financial advisor, | have been content in providing high quality
financial advice and ongoing service to my clients under this type of compensation model for 26 years. |
contact every one of my clients to provide account reviews and services at least once a year. And the
total cost for financial advice and investment products paid by my clients has been much lower than the
average costs paid by clients of advisors using the level asset based fee model.

Using the FINRA calculator tool, Fund Analyzer, a comparison of these two alternative types of
compensation models yields the following results when we assume a constant 5% rate of return on both

accounts:

Name of approach: Amount invested Total cost over 10 years Total Value after 10 years
American Balanced Fund $10,000 $1,270 $14,472

Fee Based Account $10,000 $2,441 $13,177

American Balanced Fund $250,000 $24,208 $374,296

Fee Based Account $250,000 $61,034 $329,432

Note: !'ve substituted the Oppenheimer Main Street Small Cap Fund class C as a proxy for the average
fee based account in the FINRA tool. The tool does not have the capability to demonstrate an actual! fee
based account. The total! annuai operating expense of the Oppenheimer fund is 2.12%, which is
equivalent to the total cost associated with the average fee based account using my assumptions

explained In this commentary.
See the attached document from the FINRA tool for details on the $250,000 example I’ve presented in

the above table.



Short-term trading Ho short-term trading fees apply
redemption tee

Short-term troding Hot Applicable
rederpuon tee
waivers

No non-shortaerm redevotion fers
Other
Redemption/Extheng
Fees

‘rio exchenge fees

Yo shod-totm trading fees apzty

Hat Appicabic

No ron-short-term redemption fees

Ho exchange fees

“page 07