October 27, 2010
To whom it may concern;
I am compelled to write to you today regarding File number S7-15-10, in support of the new SEC rule 12b-2 to continue the 25 basis points fee. As a licensed representative beginning my 10th year in the business, to be able to serve my clientele across the spectrum of financial means requires the continuation of the 25 basis fee. While competition based on price and cost sounds good, it will come at the expense of needed advice and service for middle market investors.
As broker-dealers lower their sales charges and fees in an effort to gain market share, it will no longer be financially feasible for registered representatives to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients. As a result, only upper-income investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice.
Avoid this inevitable trend by allowing broker-dealers to set their own commissions. Again, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount.
Thank you for your time and review of my note.