October 27, 2010
I want to voice my support for one part of the proposed changes by the SEC to 12b-1 charges and concern about allowing broker dealers to set commission levels rather than the fund managers.
I support the continued 25 basis points to compensate registered representatives for ongoing service and advice to investment clients.
However, allowing broker dealers to set their own commission rates will cause a slashing of these rates to win business and market share at the expense of providing sound advice and service to the investing public.
Certainly lower and lower sales commissions or loads for financial products sounds, at first, like a great consumer friendly idea. Except, there are currently funds known as "No Load" shares that charge no sales load. These are good options for those experienced investors that know what they are doing and require little or no help in understanding the instruments they are buying. However, most investors do not and certainly employees enrolling in a company 401K or SIMPLE IRA are seldom experienced.
"No Load" investments are also called "No Help" investments. To make all investments little or no help investments would have a negative impact on the most vulnerable of the investing community.
As a representative for over 14 years I have to say that I spend most of my Continuing Education time, Compliance Time, and Licensing and E&O cost on maintaining my securities licenses and keeping in compliance. It is highly regulated and controlled as it should be. But in order to stay in the business of assisting individuals and groups with their investing options it is important to maintain fair compensation to a licensed representative. Otherwise they will leave the marketplace and find something else that will more fairly compensate them for their time and expertise.
Rather than creating a cutthroat atmosphere of slashing commissions, it is better to have commissions fixed by the funds themselves and have representatives compete for those fixed commissions by being the best, brightest and most service oriented in the industry.
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