August 9, 2010
RE: comments regarding proposed changes to the 12b1 fees
I would like to make a few comments from my perspective as a financial advisor (FA):
1- Reputable FA's are already clearly and completely disclosing the charges that a client will pay, regardless of share class or advisory fees. Whether the fee is called 12 b1, an advisory fee, or some other name, it is used to compensate for ongoing service provided by the FA. This ongoing service after the sale is very important, and can help an investor make the right choices. Excessive regulation of these fees, rather than letting market forces determine them will ultimately limit the amount of service that investors receive after the sale is made.
2- With the SEC operating on limited staff and budget (like we all are), there are clearly areas obvious investor abuse and fraud should be focused on (multiple ponzi schemes and investment sales targeted at the elderly to name a few).
Respectfully submitted,