October 27, 2010
As a registered rep I have been licensed to sell securities almost 9 years. My customers are small investors and savers who are seeking guidance for their modest investment plans. The proposed rule S7-15-10 has some good for these people and some not good. The good is the label change of 12b- 1 fees to marketing and service fees. I think most people will not only understand the label but also understand the concept of ongoing management fees charged to cover the cost of operating the fund.
What they won't be served by is the fee issue. None of my customers will pay a fee for service. As a result they won't receive service and won't invest or save. The current compensation structure provides a uniform commission platform. If broker dealers are left to race to the bottom of pricing, or if the broker dealers simply let the registered reps set the fee, the pricing will be all over the board, and even less transparent. The current commission structure serves middle America by providing a sales and service pipeline that can afford to work with them as a result of commissions.
Thank you for your consideration in this matter.
Wade L. Scott, LUTCF
Farm Bureau Financial Services