November 1, 2010
"File Number S7-15-10"
I have been a licensed insurance agent and registered representative for over 25 years. I support the new SEC rule 12b-2 which would continue to compensate registered representatives for servicing their clients on an ongoing basis because if there is no compensation incentive the client will not get the service they NEED and DESERVE. This will then lead them to feel angry and confused and much more likely then to switch to another registered representative who will "churn" their investments and be compensated by the client AGAIN. The cycle will continue every time someone comes along with a "great story", and the client will pay AGAIN and AGAIN.
The same will be true if the SEC allows broker-dealers to set their own fees. They will lower them to gain market share which will ultimately hurt the small to mid-size client that needs advice and annual reviews more than anyone. So I STONGLY object to the SEC permitting mutual funds to issue a new share class at NAV for this purpose. This would be a law of "unintended consequences". It all sounds good until you understand the reality of the situation. The people you think you are trying to protect will get hurt the most.
After doing this for over 25 years, there is one thing I know and that is Americans will spend more time planning a week-long vacation than they will spend planning a 30-year retirement. It's not because they don't think it's important. It is because it's confusing and scary. Therefore, they will NOT do it. My small to mid-size clients are more than happy to pay a reasonable fee for my expertise and guidance in something this important. Therefore, I would strongly urge the SEC to reconsider this change due to the certainty of "unintended consequences".
Field Director/Financial Representative
Northwestern Mutual Financial Network