September 4, 2009
I am submitting my comments in response to the SEC proposed rule, 206 (4) - 5 that would ban any third party from marketing investment products to public entities. For disclosure purposes, I am a marketing professional at a $3 billion fixed income asset manager that currently does not use Third Party Marketers.
My comment regarding this proposed rule change is that it would be crippling to many small and medium sized managers that cannot afford dedicated resources or gain traction with many areas of the Public Fund universe. A structural change such as this would ultimately limit the ability for public pension plans to be aware of many of the most talented and best performing managers and products, ultimately impacting pension beneficiaries and taxpayers. Although our firm does not use third party marketers, we feel eliminating their ability in the public plan market stifles competition, and ultimately, capitalism.
I ask that you regulate the proposed "pay-to-play" practices, and not eliminate what is to many firms, a valuable and effective way to build business.