October 15, 2010
I support the proposed rule.
I am very much opposed to the way 12b-1 fees are generated from the accounts of exisiting fund shareholders and used to market broker/dealers and prospective clients. Such marketing may be a reasonable expense for fund companies to incur, but I feel it would be more honest if the cost were included in the consumer charged expense ratio, (which we can easily compare and shop), and bourne by the fund company itself as a cost of doing business.
Generally, fees and charges assessed by consumer-facing SEC registrants are obscured to the point that it is impossible for even relatively experienced investors to determine with any level of certainty what they are actually paying, in total, to fund companies and broker/dealers on an annual basis. Greater disclosure and transparency is sorely needed in this sector of the financial services industry.
When my banks charge me a fee they are required to clearly report it on my next regular statement. Brokerage firms and fund companies should be required to do the same, (in dollars and cents and as a percentage of assets). At a minimum, I should receive an annual fees and expenses statement from all of the funds I am invested in so I can compare the true cost to me of the service they are providing. This would allow me to determine if I am receiving acceptable value from them.
In conclusion, I support the proposed rule as a first step in a much-needed process toward more consumer-friendly disclosure by the securities industry. Ultimately, however, I think you should be talking about eliminating 12b-1 fees altogether.