August 5, 2010
I believe the proposed 12(b)-1 fee change will hurt investors seeking professional financial planning advice. As an example, a young family wanted to seek advice from a financial planner and they have $10,000 to invest into mutual funds. A class C share fund offers them a way of investing without paying an upfront fee and their money goes to work in the fund right away. The fund then pays the advisory company approximately $100 in commission. Of this $100 in commission, on average 75% goes to the financial planner after the broker dealer takes there share. Now the planner has made $75 in commission for 2 to 4 hours of work. With a class C share the advisor would be compensated $75 per year on an ongoing basis to service this clients planning needs. Under the new proposed regulations, the C share would reduce fees to $25 per year after 4 years (converting to an A share) and the advisor would receive $18 per $10,000 under management. This is not enough compensation to manage a business and help the client with their planning needs.
Advisors would need to start charging planning fees to clients. The small investor would be hurt the most based on these new proposals. The small advisor who is starting into a planning career would also be hurt.
I would recommend not changing the fee structure payout on a class C share fund. One possible change would be to name from 12(b)-1 fee an advisory fee instead.