October 30, 2010
File Number S7-15-10
I have been a licensed Life, Annuity, Health Ins, and Registered Representative for 20 years. With the Health care changes that will cut my Health commissions, based on the information that health care providers are saying that will happen based on the Health care bill, along with the possibility of loosing my 12b1 fees, I stand to loose 25% of my current income. So I am very happy to see that the new proposed 12b1 fee that would continue the 25 basis point fee.
As I understand the proposed change, the name may change and there will be more transparency if the changes are put in place. And if you want more transparency, have the prospectus written in client friendly English. Perhaps more of my clients would actually read the prospectus in stead of throwing them away. It's a waste of natural resources if the client doesn't understand the language in the prospectus.
However, I disagree with the plan to allow Broker Dealers to issue new share classes and set lower sales charges in an effort to level the competition between Broker Dealers. My clients are generally middle income, with amounts under $50,000 to invest. It will no longer be financially feasible for me to offer the advise that my clients have come to expect. The few higher income clients I have that can afford higher cost and higher service classes of shares will expect the same service as my lower income class clients. But if I understand the proposed change I will no longer be compensated to offer the advise and services to my smaller investors because the compensation will be less.
The Share Class A B rules are already unfair to a client who opens a small account to begin with and requires me to sell the client a B share. But I know the client has plans to add additional funds in the future that that would make the B share wrong because of the break points that an A share class offers. So in the long run, I cause my client to pay a higher cost just because I can't prove the client plans to add additional money on the day I write the application.
Most of my small account clients are not, and will not, have the knowledge to use self directed funds. That's why they come to me for the advise and knowledge I provide.
With out a fair compensation for the small account client, who still expects advise, why would I continue to provide advise if there isn't something in it for me to compensate me for my time? Less than 20 of my clients are even signed up for electronic delivery of statements and prospectuses, so I doubt they will spend the time to self direct their funds on line.....
By trying to protect the small investor with lower cost funds, the proposed SEC changes will do more harm than good. Additional share classes will confuse clients more than they are now.
To often the effort to protect the low and middle class share holder ultimately is more harmful than the expected out come.