October 27, 2010
File Number S7-15-10
I am a licensed insurance professional. I am writing to let you know my stance on the recently issued proposed rule that would reform SEC Rule 12b-1.
While I support the new SEC rule 12b-2 which will improve transparency in disclosure documents by changing the current terms "12b-1 fees" to "marketing and service fees" and "ongoing sales charge", I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value.
If a new class of shares is permitted, in an effort to gain a competitive market share, the broker dealers will slash their fees. When that happens, it will no longer be financially feasible for registered representatives with smaller fund account balances to continue to provide the level of individualized advice and services they currently offer their clients. The result of the SEC permitting mutual funds to issue a new class of shares will cause the middle market investors to be hurt the most and they will be deprived of the guidance they need and deserve.
As a licensed insurance agent, I ask you to reconsider the proposed changes to SEC Rule 12b-1.
Dallas Bokop, Insurance Broker