September 27, 2010
I recently returned from my broker/dealer`s annual conference and am concerned about what was presented regarding 12b-1 fees, particularly with regard to class "C" shares.
I have many clients who choose these shares over the corresponding "A" shares and fee-based accounts. They like the flexibility the share class gives us to make changes without adding to their costs, and often a portfolio of "C" shares has total costs that are lower than a fee-based account with no-load and/or load-waived "A" shares.
A typical client relationship might be as follows: A $100,000 brokerage account invested in "C" shares of five or six different mutual fund families. This account pays me $800-$850 per year after my broker/dealer`s split. I meet with the clients at least annually, where I review the account and complete a profile that details the clients` net worth and retirement income analysis. They rely on me to monitor and recommend allocations for their employer retirement plans, as well as provide advice on a range of financial topics throughout the year. This is in addtion to managing the account for which I am actually paid.
As I understand the proposed changes, at some point the "C" share trail would change to 0.25%. This would reduce my net compensation in the example above to $200-$212 per year. At that rate, I simply can not competently serve the number of clients required to make an adequate income to cover my business expenses and support my family. I would be forced to stop servicing smaller accounts and focus my efforts on acquiring larger accounts. In reality, a high percentage of the people I serve have less assets for me to manage than in the example above.
Please consider the effect that these proposed changes would have on the ability of smaller investors to obtain competent financial advice and the ability of advisors to maintain high-quality service to a reasonable number of non-affluent clients.
Mr. Mark Boukather
Hawkins & Boukather, LLC