Dear Mr. Katz,

This is a letter to support continued payment by Mutual Fund companies of 12b1 fees to brokers/broker dealers for servicing clients. My practice has 300 clients. Some accounts require several meetings per year to review asset allocation, the appropriateness of funds to a clients changing circumstance and needs, making sure beneficiaries on qualified accounts are still up to date, changing banks for automatic bank drafts, reevaluating whether a given client is saving enough or has enough money to retire, whether a client should add to their retirement account or save through non-pension accounts.

Each client has different needs. Our office proactively calls clients to set up reviews. We also receive calls from clients that want to go over their accounts. I do not know how we would be able to offer the level of service we offer without service fees paid through 12b1.

I believe reducing or eliminating these fees will mean the loss of jobs of those people instrumental in helping people keep on track of their financial goals. It will also encourage churning and the wholesale movement of client assets to managed accounts which typically require a significantly higher fee to the client. Those clients who do not pay the higher fee will not get service or planning -- much to their detriment, whether they realize it over the short term or not.

I was at a conference recently that indicated that the hold period for funds sold through a broker was roughly double than the hold period of an investment purchased without a broker.

It is no surprise to me. We are paid a 12b1 fee to keep people in appropriate investments, to monitor these investments and to do regular reviews with the clients. A knowledgeable client is a happy client. A happy client does not switch investments every 3 years.

Please understand that the 12b1 fees play a pivotal role in giving ongoing service to our clients. And ongoing service has a direct relationship with investors staying in their investments long enough to experience the published returns of a portfolio rather than a mere fraction of the published returns because a rocky market spooked them out of their positions.


Kenneth T. Podell Registered Representative MML Investment Services, Inc.