October 27, 2010
File Number S7-15-10
I've been a registered rep for five years. I fully support being transparent about the 25 basis points, and I recommend calling it an ongoing service fee. If there is no service, then the client should seek help elsewhere. I would like to see the service charges deducted DAILY by the fund company rather than quarterly as it can have less of an effect on average performance. Then, each statement should clearly show what has been deducted for advice.
The ABC share class model should be scrapped and I support the proposal of allowing BDs to set charges based on the service they provide. The current upfront sales charge compensates advisors once in a lump sum and then the incentive to service the account is reduced in the future. I'd prefer to charge clients 25-100 basis points on top of NAV and never have an upfront or back end load.
I'd adjust the basis points based on account balance. This would be fair to clients and fair to me, as my performance and service is linked to their long term success.