July 23, 2010
I fully support the SEC proposal to implement limitations on mutual fund distribution fees. I feel the most important aspect of this proposal is the improvement of transparency. Investor statements should show all costs associated with owning a fund and give an explanation of what the expenses cover. There is much talk that this proposal will inspire an industry response that will negatively impact the small investor as advisors increase their minimum account size to counteract the loss of 12b-1 income. Perhaps the SEC and FINRA should be proactive and research the various industry practices that encourage discrimination against investors of a lower net worth and find a way to end these industry practices. I am using the word "discrimination" loosely to describe practices such as high minimum account sizes and higher fees as a percentage of assets for smaller accounts and high gross production requirements. Smaller investors need the help of a good financial advisor as much, if not more, than the wealthy. It is extremely difficult for an advisor to utilize a good broker-dealer with strong support and research services if they focus on this market because the good broker-dealers want to focus on larger clients. To focus only on expenses and transparency without addressing the greed and discrimination only further encourages a disparity of wealth in our nation.