October 27, 2010
I have been a licensed insurance professional and registered representative for over 14 years.
I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.
I have always taken care to explain sales charges and internal costs to my clients as part of the educational and due diligence process undertaken as I assist them. Making these details even more transparent is helpful.
However, 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.
Competition based on price and cost sounds good but will come at the expense of needed advice and service for middle market investors. And this education and service is very much needed at this level as most consumers have had little or no exposure to issues relating to investments in the course of their high-school and college educations. This issue causes me great concern as responsibility for financial decision making, including health care and insurance as well as investments and retirement planning, falls squarely on the shoulders of the consumer much moreso at this time than ever before
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.
Investors with smaller fund account balances will be forced to self-direct their accounts if they wish to continue to own mutual funds because their advisors will no longer be able to afford to spend the time to guide and advise them, leaving discount brokerage fund platforms as the only affordable option for middle and lower market investors.
The people the SEC is trying to protect the most--middle and lower market investors—will be hurt the most, since they will be deprived of the guidance and service they need and deserve.
My colleagues and I currently fill that educational gap and I have always been commended and thanked for my efforts by my clients. The usual comment is, " I've never really known much about investing and I appreciate the time you've taken to explain it". We need to be able to continue to provide that service until such time as consumer economics and personal financial management become required courses of study in our schools.
Thank you for your thoughtful consideration of my views.