November 2, 2010
I have been a licensed insurance professional and registered representative for over 30 years.
It has always been important for us to be able to provide good service and client advice to all market levels. We often work with NON-affluent clients. I can support the propsed rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.
But, I am opposed to letting BDs name their own commission and service fees. It will be a disaster for our middle market. People in general already make most purchases on the basis of the "China-effect" of buy cheap and expect to repeat. I am confident this will drive down compensation too far to provide personal service and this is the market that needs it the most. Look at how the general population has done managing their own 401k portfolio's...another disaster. Many of the middle market accounts are too small to provide fee-based work and we cannot abandon them to themselves. They are among the least likely to succeed in the absence of good service and advice.
Help to preserve this middle market by not changing this provision.