From: Clifton Morris Jr. |
Sirs: I'm a Minority owned BD and Investment Advisory Firm, which is state registered. The BD is a Limited BD's (ICS, VA, VL ,DPP) which has over 30 million of assets subject to 12b1 (.25 basis points). 3/4 of these assets are in one family so my clients can maximize breakpoints. the fees are critical for ongoing services to clients. If your interested in killing small BD's, fooling around with revenue flows will force & encourage the use of wrap programs which would double or quadruple client costs. For those of us who remember you used 12b1 to cut share max front load from 8.5% to 5.5%. Now you want to kill the only thing which encourages building client relationships which is not transaction based.. Most of the new rep's out here are totally transaction centered, which I can attest does not encourage long term client relationship.- Keep it up and the SRO's problems with "Breakpoints, Variable Products, and other contentious issues revolving around pay will simply be intensified. If you must, simply move back to the 25 -50 basis point max and get rid of 'C' shares or force additional disclosures. Be careful of unintended consequences!! Clifton Morris Jr., CLU, ChFC |