November 2, 2010
FILE NUMBER S7-15-10
I have been a licensed registered representative and an insurance provider for 17 years. I do support the new 12b-2 fees by using the terms of 'marketing and service fees" I live in an area where fee based plans will just not be acceptable and are not in the best interest of the client because I work with tens of thousands of dollars not $100,000 or millions. People buy mutual funds and usually hold for retirement planning. I do meet regularly, and the 25 basis point fee is very important for my business. Usually pretty low to the service I provide, but such is life. I do disagree with permitting the mutual funds to issue a new class of shares that would allow the B/D to set their own sales charge. This will be like a bidding war. It will not be financially feasible for me to even continue in business. The expenses keep rising and the cost of health care is deadly. As an advisor, I will no longer be able to afford to spend time with clients and guiding them. I work with smaller investors. It seems like those who want to help and/or protect will be hurt the most. They will have to go direct to a fund, with no advise or help. Those people with out talking to an advisor, sell out at the worst time, when the market is down. A few years ago, I heard a statistic that investors directly with a fund lose more money because of fear so they sell off, than those who work with an advisor. The advisor might help tweek the fund or help them to understand why they need to ride it out. MOst people need hand holding.I never know what I will make when I work with a client. My philosophy has always been, if I do a just service to the client, I will be compensated. I haven't starved yet. I don't have a big business, but it has allowed me to be content. Once again, I feel a government agency is trying to break the small business owner, and the smaller investor.
Thank you for your reconsideration to allowing B/D to set their own commission. YOu will not be serving all the people who invest into the market, including IRA, ROTH IRA, and SIMPLE plans, 529 plan, and custodial plans that are for the mid -smaller investor.
Freitag Financial Services