October 27, 2010
I have been a licensed registered rep serving individual clients for over 13 years. I support the new SEC rule 12b-2. This would allow me to continue serving my clients and giving them the individual customized advice that they deserve. I strongly oppose the SEC permitting mutual funds to issue a new class of shares at net asset value and allowing broker-dealers to set their own sales charge and commission amounts. It is obviously healthy to make sure that fees remain reasonable for the services provided but a rush to assume that costs are the only thing that an investor should be considering when they make investment decisions would be a mistake. There are already plenty of outlets for people who want access to low cost no advice investing. This new proposal would unnecessarily force priorities to be rearranged as everything moved to this cost only approach. My clients know they have other options to turn to if they do not think my services are worth the cost. I have never had a complaint. It is my request that the options I have to present to my clients are not limited in this way. This will hurt my middle class clients by forcing me to switch to a fee-only approach. Many of these middle class clients would not be willing to do business in this way, and based on my experience would not continue to save for their future if left on their own without access to good advice.