October 28, 2010
I have been a licensed insurance professional and registered representative for 20 years. And I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.
That being said, I object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount. Competition based on price and cost sounds good but will come at the expense of needed advice and service for middle market investors.
As broker-dealers lower their sales charges and fees in an effort to gain market share, it will no longer be financially feasible for registered representatives to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients.
Investors have been hurt enough by the economic downturn and investors with smaller fund account balances will 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 advise them, leaving discount brokerage fund platforms as the only affordable option for middle and lower market investors.
In my 20 years in this business, I have seen insurance companies try to cut costs by going directly to the consumer and it has not worked well. We all need professionals to counsel us and urge us to do the things that are right for us. The better an individual is able to be shown how to solve their own needs, the less pressure there will be for public programs to provide benefits.
The oddity is that the people the SEC is trying to protect the most—will be hurt the most, since smaller account owners will be deprived of the guidance and service they need and deserve.