November 4, 2010
12b-1 fees should remain as they are. They allow advisors to provide cost effective services to those with assets in the $10K-$100K level in particular - clients who would otherwise not be able to afford the advice of a top financial planner. Our firm services somewhere around 800 or more clients with assets in this range without any additional charge other than the 1% a year 12b-1 fee. The fee is fully disclosed as pre-tax and less than our normal fee of up to 1.5% on larger accounts. We only recommend c-share investments at this reduced fee to allow middle class people access to financial planning services. If this rule is changed, we will not be able to serve worthy clients in this asset range. The 12b-1 actually helps people receive services for a lower cost - it keeps our costs down by eliminating billing, and advisory and other product we recommend to those with higher assets cost too much and generally have investment minimums that lower dollar investors cannot meet. The fees are fully disclosed to our clients, so our clients do know a fee is being paid. You will be hurting those that actually need help the most if this rule is approved. Make disclosure of the fees more transparent - to show not only the reps fee, but the other fees and expenses if it is believed they are not clear enough --but do not get rid of the 12b-1 fees. Also, the ability to have the fees deducted from the account without requiring billing of the fees and outside agreements helps to contain costs and is another piece that allows us to serve lower level investors. This is a group of investors that really, really need the help of a financial professional, yet are already very underserved as many advisors only seek to help the wealthy. The ongoing fee works well to keep financial professionals providing ongoing service to clients without any incentive to recommend trades unnecessarily just to generate additional fees for a new purchase. The advisor should be compensated in an ongoing fashion for these accounts.