June 6, 2004
I understand that the comment period is closed, but this topic is one I feel extremely strongly about. I own and operate a small financial advisory practice in a rural area of Ohio. The majority of my revenue comes from trails 12b-1 fees. As a small office, if 12b-1 fees are eliminated we will certainly close our doors. We could never hope to reach a break even point relying on commissions from new sales.
My practice has been built on 20 years of efforts and an emphasis -- over about the past 5 years -- on building a book of high 12b-1 business. Other than commissions from transactions and 12b-1 fees, we receive no other compensation. Here are the benefits my clients recieve from this ongoing revenue stream provided by 12b-1 fees, as we charge no fees for ongoing service:
1. Quarterly, semi-annual, or annual meetings.
2. Periodic investment re-balancing.
3. Customized reports.
4. No cost financial advise on everything from buying a car to which type of siding to put on their house to whether to refinance their home.
5. Binder maintenance -- keeping an organized binder for all financial information.
6. Retirement plan allocation.
7. Spending advise and tips.
8. Invitations to ongoing educational events seminars, client apprecaition days, etc..
9. Help with income tax document preparation.
10. RMD calculation and management.
These are services whcih my older, mainly retired client base has come to expect and rely on. My 500+ clients can not be served if the 12b-1 fees that support this level of service are eliminaated.
I urge you to carefully review this policy. Not only will the removal of 12b-1 fees force several people in my office to become unemployed, it will severely impact the financial lives and positions of our clients. I honestly believe many of these clients need our advise and help, and we CANNOT survive without 12b-1 fees.
Registered Investment Advisor
FSC Securities Corporation