March 1, 2004
In regards to SEC Rules 15c 2-2 and 15c 2-3 currently under consideration, it is my understanding that one provision would eliminate 12b-1 fees.
Having based my business and money management practice on an income stream from 12b-1 fees, rather than having the client pay a much larger front end fee, I feel I am providing my clients with the most cost effective approach to paying for my services while still allowing me to generate enough income to operate my business and provide for my family. Given a choice of share class the majority of my clients, who invest under 100,000 on average, consistently choose Class C shares with no initial sales charge, a one year CDSC, and ongoing 12b-1 fees as the preferred structure. In order to provide my clients with this choice, the 12b-1 fees must stay in place as they currently exist in order to offset the huge loss of inital commission that sales of Class A shares would provide. Thankyou for your time.
Sincerely, Eric Jahnke