October 27, 2010
I have read the proposed changes the SEC wishes to make to the 12b-1 fees. Although in principle I understand the desire to make this transparent to the consumer, I am most concerned with allowing the broker/dealers to set their own commissions and sales charges in order to compete based on their levels of service. The affluent client doesn't hold the type of accounts that you would be negotiating these types of commission and sales based charges on. They hold accounts in management accounts that require as the fiduciary that we provide on-going service for our fee. However, once the sale is made to our middle market client, that same level of service may or may not be provided, but if there is not compensation for the registered representative I can assure you we wouldn't have time to give the high level of service we currently are able to offer. It would clearly cause the broker/dealers to race to the bottom to get all the assets under management they could in order to make a profit. There is a very narrow margin profit on that particular type of product as it stands. Therefore, I believe this is an issue that deserves further consideration, and must be considered thinking of the end in mind. That is, how do we obtain high levels of service and investment advice for the average Joe. It is not by reducing an already level playing field with regard to the commissions and sales charges. You need to consider what they need the most going forward and that is professional advice to help them muddle through this economy and get back on their feet. Not to throw a penny into a wishing well and hope it turns into something for retirement, college education for their children, or buying their first home.
Georgianna (Shelly) Latino