March 3, 2004
Having just learned of the extensive and detailed proposed changes to mutual fund fess and compensation in the midst of federal tax season demands, we request that you please extend the review time from 60 to 120 days so that further careful evaluation of the impact of such proposals upon our business is possible.
Appropriate disclosure of fees and compensation already exists within each prospectus. Commissions have been dramatically cut and rearranged in recent years from the original front end levels of 8.5 percent, in favor of a compensation structure that encourages continuous service after the sale - i.e. long term relationships rather that transactional relationships.
At this point I am shocked to see any proposal to reduce or even eliminate 12b-1 fees. Such fees are specific compensation and a strong incentive for registered representatives to continue serving clients. Removing them would not have the desired effect of regulators who would then be legitmately concerned about the lack of Reg. Reps. service after the sale. Focus upon immediate transactions rather than long term relationships would then be the obvious consequence and much more detrimental to any investor.
Such radical regulations upon 12b-1 fees will also have a definate negative impact upon the income of those representatives who have worked hard for many years to build a loyal and stable client base and who honorably continue working past retirement age to maintain their own support and independence. Eliminating 12b-1 fees forces them towards becoming more dependent upon government programs for support at a time when the federal governmentdue to lack of sufficient funds is extending the eligibility age for social security benefits, providing tax incentives for self-funding of long term care plans and encouraging senior citzens to continue working by reducing income tax penalties on those receiving social security retirement benefits.
These are just a few things that immediately come to mind without adequate time to really evaluate the total impact of these current proposals no matter how well-intended. Please allow for a thoughtful rather than an impulsive process by at least extending the time for serious input.