October 27, 2010
I have been a licensed professional representative for over 30 years. I do support the new SEC rule 12b-2. I feel that the continuation of the 25 basis points will ensure investors receive ongoing service and advice. I do believe in improving transparency and the disclosure documents by using the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1" fees. However, I strongly disagree that the SEC permit mutual funds to issue a new class of shares at net asset value which would allow broker-dealers to set their own sales charge and commission amount. On the surface this may appear good for competition based on price and costs, however, it will come at the expense of advice and service for the middle market investors. What will happen is broker-dealers will lower the sales charges and fees in order to gain market share. It will no longer be financially feasible for registered representative such as myself to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients This would mean that only the upper income investors who can afford asset under management arrangements will receive personalized investment advice. A good portion of my clients are in the middle and lower market,the financial reality for me is that it will not be feasible for me to continue the level of service and guidance as I have done in the past.