September 27, 2010
I would like to comment on the proposed changes to C Share class of mutual fund 12-b 1 fees. Although it seems that your regulators are attempting to increase competition and enhance the trasparency to the clients -- the law of "unintended consequences" will most certainly prevail.
Our firm is a fee-based asset mgmt financial planning organization that utilized both fee and commission accounts. Our on-going small annual service fee provides our firm with the incentive to provide ethical investment advice without any large upfront commissions to alter our judgement or recommedations. We use C shares as a substitute for those clients that do not have the account minimums that are required for true fee accounts. By eliminating the on-going trail on C shares, we will simply stop serving this middle market. Who will fill in for us? It will be the true commission broker who is more interested in getting an upfront 5% commission than serving the on-going financial needs of their clients.
PLEASE STOP THIS PROPOSAL THAT WILL ONLY HURT THE MIDDLE MARKET AND DRIVE THE TRUE INVESTMENT PROFESSIONALS OUT THAT ARE CURRENTLY WELL SERVING THIS MARKET!
Mr. Thomas A. Gray, MBA
Triad Advisors, Inc