October 28, 2010
I have been a licensed Insurance professional and Registered Rep for 22 years. I support the SEC Rule 12b-2 , which continues the 25 basis points fee used to ensure investors receive ongoing service and advice, and the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to imporvoe disclosure documents.
However, I Strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow b/d to set their own sales charge and commission amount. Competition is good, but not in this case. It comes at the expense of needed advice and service to middle market investors.
It will come at a cost to registered reps to help the investors who need it the most The upper income investors will attain all the attention of the reps, since they are the paying customers. The middle to lower investors will suffer, from advice and potential gains due to the lack of advice and direction given by the Registered Rep.
Investors have been hurt enough with the economic downturn. This is a business of Customer Service, but the registered rep must be paid for the efforts, or it will create an even bigger downturn for so many middle or lower investors.
The better service that can be provided to the middle and lower investors by the registered reps, the less of a need of public programs trying to help these investors overcome their investors needs. It will hurt the ones you are trying to help the most. Guidance and direction is provided by the registered representatives to all classes of people. The middle and lower investors need more, in order to get where the upper investors are today