October 27, 2010
I have been a registered representative for over 40 years. I hold Series 7,24,63 and 65 registrations. I support the new SEC rule 12b-2 which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SEC's proposed used of the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees" to improve transparency in disclosure documents. However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at NAV. This sounds good but will come at the expense of needed advise and and service for middle markekt investors. Most of my security clients do not have large enough accounts to be able to have a fee based program and without a sales charge I would not be able to provide the service and advice they need. As a result only upper-income investors who have advisory accounts would benefit. It is my understanding the people the SEC are trying to protect the most are middle and lower market investors would be hurt the most as they would be deprived of the guidance and service they need and deserve.
Thank you for the work you do and for allowing me to express my opinion on this important issue.