November 2, 2010
I support the adoption of the more descriptive names for 12b-1 fees namely the adoption of the term ongoing sales charge as an appropriate description on the continuing commission charge for a clients mutual fund account. I also support the adoption of the 25 bps safe harbor for the marketing and service fee. I can support the adoption of common sense improvements to marketing and service fees within the prospectus but oppose the additional confirmation statement which is overly burdensome without a clear benefit for the client.
I oppose the cap on on-going sales charges. I believe that smaller account investors need ongoing support, advice, and service and the on-going sale charge is an efficient vehicle for compensating registered representatives for their service.