October 27, 2010
Subject: File Number S7-15-10
I have beena Licensed Insurance agent for more then 22 years.
I support the new SEC rule 12b-2 which would continue the 25 basis points fee that is used to ensure investors receive ongoing services and advice, and the SEC's proposed use of the terms "marketing and service fees" and "on going sales charge" in place of "12b-1 fees" This would give a more transparent understanding to the general person so that they would know what the charges actually are for.
However i do object to the SEC permitting Mutual fund to issue a new class of shares at net asset value that would allow broker dearlers to set their own sales charges and commission amount.
Competition based on price sounds good but would cause broker-dealers to steer client to an in house Mutual fund as apposed to recommending a more diversified portfolia and could also cause a diminished quality in the advice by which the client could receive.By choosing what we charge the client my fear is that the middle market client will receive less advice and service and the more affluent client would only be benefited.