October 27, 2010
Thank you for the opportunity to comment on the proposed rule 12b-2.
Using the term "marketing fees" does make it more clear than the current term 12b-1 and a client should know what the fees are.
However, I am opposed to the part of this proposal that would allow broker/dealers to establish fees. We saw this type of pricing in the large group market which is exactly what drove the former NY Attorney General to go after several large health insurance brokers in the past....basically it became a rate fixing game. In this case the concern is that the lower the fee the opportunity to obtain the business seems good for the client however once the business is on the books the concern becomes on-going client service. Additionally what is to stop a large national broker/'dealer from "low balling" the fees to drive the good regional broker/dealers out of the market. Middle America needs personalized service which is what is provided from these broker/dealers. The large wire house broker/dealers appear to be less concerned with client service for the smaller client than they are market share. Middle income clients don't always use fee-based planners, in some cases this type of client would not use a fee-based representative for that reason....they don't want to pay a fee. This approach appears to be fraught with problems and is of great concerns to me.
I urge you to amend the proposal to remove this approach.
Thank you for this opportunity to comment.
Lorne Hargis CLU ChFC
Mill Ridge Insurance Planning Agency