March 11, 2004
To whom it may concern:
I am a Certified Financial Planner for 28 years. I work with all levels of income and net worth. I am able to do this for Middle America because I receive 12B 1 fees to help offset my service costs.
If the proposed SEC Rules 15c2-2 and 15c2-3 discontinue 12B-1 fees, I will have to bill these clients for my services.
As you may be aware, many Middle America clients do not have discresionary funds to pay fees.
In regards to full disclosure, I support full disclosure and I currently provide full disclosure using the mutual fund prospectuses.
Lastly, I believe there should be three 3 ways to purchase mutual funds: A shares for long term buy and hold investors, C shares for short term 1-3 yearsbuy and hold investors and Advisory Shares @ NAV for actively managed investors.
Please try not to effect the financial planner from servicing Middle America. They need our services more than ever.
Daniel W. Leveroni, CFP