October 28, 2010
I'm writing this letter as my response to the new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors ongoing service and advice and the proposed use of new terms to improve transparency in the disclosure documents. As a licensed insurance professional and registered representative for over 30 years I support the above changes, however, I strongly 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. I pride myself in the service and advice that I provide to my clients and they in return appreciate what I do for them. However, I see this as a problem in the future if I have to try to save them from other agents that will try to "BUY THEM" with lower costs, forcing me to lower my costs to them and then not being able to afford the type of services they are accustomed to. The agents trying to BUY THEM are usually the new agents who don't have any experience in the market place and cannot provide what I do. The client is the one who will suffer in the end. Less service or none at all, poorer advice, and ultimately lower returns. Once soured, they will blame all investment advisors and nothing good will come from this part of the bill. The middle and lower market investors that you are trying to protect will be the exact people that you will hurt the most. Don't deprive these investors of the guidance and service they need and deserve in the name of competition. It doesn't work that way in real life.