November 2, 2010
RE: File Number S7-15-10
I believe I have the credibility to address the issues surrounding File Number S7-15-10 since I have been a licensed insurance professional and investment advisor representative for over 11 years and in the financial, tax and accounting world for another 30 years.
I do support the new SEC Rule 12B-2 EXCEPT where the SEC is permitting mututal funds to issue new class shres at NAV that would allow broker-dealers (BD's) to set their own sales charge and commission amount. TALK ABOUT OPENING A CAN OF WORMS.
Competition based on price and cost is usually good but NOT AT THE EXPENSE OF NEEDED ADVICE AND SERVICE FOR MIDDLE MARKET INVESTORS...which by the way is mostly what my practice is made up of.
If BD's lower their sales charges and fees, there will be a PRICE WAR. Can't you just see it now: The middle guy will be pushed out because they cannot afford the ADVICE and SERVICES we as advisors provide. And we advisors will be out of business unless our entire book of business is with high net worth clients. We would not be able to service our middle guy/gal clients because the BD's have had a price cutting war and we advisors cannot make a living giving FREE ADVICE. As a result, the only clients getting serviced will be the upper-income investors who can afford assets under management arrangements or high cost/higher service classes of shares so they can continue to receive personalize advice. Won't that be great: THE RICH GET RICHER AND THE MIDDLE CLASS GET LEFT OUT IN THE COLD to SELF DIRECT their accounts with NO ADVICE if they wish to own mutual funds. Discount brokerage houses will CHEER as that is the only platform these unfortunate middle to lower market investors will be able to afford
Unfortunately, the people the SEC is trying to protect the most - middle and lower market investors - will be hurt the most since they will be deprived of the gudance and service they need and deserve