October 28, 2010
Dear Ms. Murphy,
I have been a licensed insurance professional and registered representative for twenty-eight years and want you to know that I fully support the SECs new rule 12b-2 which would continue the 25 basis points fee while creating new terminology that better defines what this fee is for and having an environment that improves transparency.
However, I'm strongly opposed to the SEC permitting mutual funds to issue a new share class at NAV that would allow broker/dealers to set their own sales charges and commissions. Competition based on price and cost sounds good, but it will come at the expense of needed advice and service for the middle market investors.
As B/Ds lower their sales charges and fees in efforts to gain market share, it will no longer be financially feasible for Registered Reps to continue to provide the level of individual advice and ongoing services that we currently provide to the middle and lower market clients. Those clients may be forced to self direct their accounts if they wish to continue to own mutual funds because their advisors will no longer be able to afford to spend the time to guide and advice them, leaving them discount brokerage platforms as the only affordable option to those investors.
Therefore, the people that the SEC is trying to protect the most-middle and lower market investors-will be hurt the most, since they will be deprived of the guidance and services they need and deserve.
Thanks for taking the time to review my comments and hopefully the best will come out of your impending decision. Have a great day!
Daniel N. Steinberg, CLU
Chartered Financial Consultant
Co-President & CEO
Savage & Associates, Inc.