May 7, 2004
I had been a registered representative since 1986 and have used mutual funds for clients portfolios since then. I feel to completely rescind the rule 12b-1 would be a disservice to about 250 of my clients. These are clients who have regular contact with me and have come to rely on my advice not only for investments but also for many of their financial decisions. The only compensation I receive for this valuable advice is from 12b-1. I would probably not continue to service or advise these accounts since even the small amount of compensation would be eliminated.
I believe in and practice full disclosure of fees. Why not consider more full disclosure of how these fees impact a clients account and let them decide whether the service is worth the cost?
From the comments about File No. S7-09-04 that I have read so far, it seems clear that the complete elimination of the 12b-1rule would force most advisors to stop advising the clients from whom they only receive 12b-1compensation. In a time when most Americans need and want help with the dizzying array of financial choices in their lives, why create a situation where millions of investors will most likely not continue to receive the advice they need?
Rick Sany, CFS
Registered Principal of SunAmerica Securities, Inc.