March 1, 2004
Please note that the proposed rules 15c2-2 and 15c2-3 are over 100 pages long and take a considerable amount of time to read and fully understand. It is imperative that the SEC extend the 60-day comment period to at LEAST 120 days. Additionally, the possible elimination of 12b-1 fees would unfairly punish the honest commission-based representative who strives to serve his/her clients. That representative deserves an on-going fee to compensate him/her for the on-going service provided. If the fees were eliminated I fear that more reps would just go to the sell everything in sight mode regardless if it serves the client. Actually, there would not be any more clients--just transaction based customers.