October 27, 2010
Dear SEC representative,
I am a concerned citizen contacting you rgarding ruel 12-1b and proposed changes.
The SEC recently issued a proposed rule would reform SEC Rule 12b-1 and the fees that are authorized under that rule. The proposed rule would maintain (but rename as new rule 12b-2) the 25 basis points fee that is currently used to compensate registered reps for providing important ongoing services to their clients. The proposal would also attempt to improve the transparency of distribution and marketing fees that are disclosed to consumers by, among other things, abandoning the use of the term 12b-1 fees and replacing it with the terms marketing and service fees and ongoing sales charge.
As a NAIFA member, I support these parts of the proposal.
However the compensation changes will create problems for consumers.A part of the proposed SAC rule claims these changes would encourage retail price competition.
If b/ds slash their fees in an effort to gain market share, it will no longer be financially feasible for registered reps to continue to provide the level of individualized advice and services currently offered. Investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice, while middle market investors will be deprived of the guidance they need and deserve.
Please do NOT implement these changes. Thank you for your consideration.
Todd Grove, CLTC, LTCP