July 22, 2010
Dear Ms. Shapiro and SEC staff,
I have been a Registered Rep in a town of 25,000 in Nebraska for 23 years. Prior to that I ran a commercial bank in this same community. I got in this business many years ago because I knew that there had to be a better way for investors to make money than buying/selling stocks that brokers were hawking back then for commissions, and that was the"managed money" route via mutual funds. Using an asset allocation approach coupled with annual reviews, myself and my two partners oversee approx. $450 million, something that we are very proud to have accomplished. I personnally manage $250 million, earning $850-900 thousand in service fees from this book of business through our broker/dealer LPL., which equates to around 35 basis points. This is accomplished primarily via American funds @ 80bps. to the client, Fidelity Advisor "T" shares @130bps, and Franklin "C" shares for bonds @110bps to the client. The average all-in cost is usually around 1.0% to the client, as I would also hold some individual bonds in a plain vanilla bond ladder that have no fees associated with it. We tend to use the American funds when we have a million dollar investment thus no front-end charge,and the Fidelity/Franklin if we have a lessor amount wherby they have lower breakpoints or none in the case of Franklin. Hopefully you can see that we have been mindful of both front-end and ongoing fees for our clients
As I said at the outset I have been doing this for 23 years, with these assets on the books for a similar long tenure. Your proposed cutting out anything over a 25bp sevice fee will cause a $125000 reduction in the gross fees received from my book(T@Cshares), that will not work given the asset compression that everyone in this business has been dealing with. I would be forced to turn all accounts into advisory/fee based accounts, which will increase my revenue from 35bps to 70bps(a range of 50-100bp fee to the account,which would increase the all-in fee to the client closer to 1.5% after adding the fund cost at 40-60bps, all in an environment where returns on financial assets could remain below average for some time. In conclusion, I hope you truly understand the ramifications of what you are proposing to most investors. Thank you Doug Oakeson.