September 15, 2010
In response to the proposed limitation and changes to 12b-1 fees I must write to disagree with this proposal. It will most definitely injure the clients you are seeking most to help.
Despite popular beliefs that managing money is so easy a baby can do it, many clients are very poor investors. They react to things at exactly the wrong time and in the wrong way. They chase performance and then bail when the market is at the bottom and poised for growth.
Also contrary to popular belief, I am not getting rich off of 12b-1 fees. But I do see them as a form of compensation for staying in touch with those clients who cannot or will not sign up for fee based investment expertise.
With most of my smaller clients this fee provides gas and time money for staying in touch at least once if not twice a year. It pays me for all the questions I answer throughout the year that have nothing to do with investing. I don`t want to become like an attorney who bills in 15 minute increments and the 12b-1 fee allows me to avoid that.
The wealthier clients, who honestly have access to many sources of advice and the money to pay for it, will usually select a fee based program that keeps me in touch throughout the year many times.
If we are being encouraged to take a more fiduciary approach to all our clients, taking away the 12b-1 fee, or limiting its duration, takes away any compensation I might receive, short of selling some other product just to generate a commission, which is exactly the procedure we are all trying to avoid.
I hope this provides a middle class financial advisor`s perspective on the impact of limiting or reducing these fees. You will see poorer service for those clients that need it most.
Investors Capital Corp.