From: JoNell Hermanson
Nancy M. Morris, Secretary
As a member of the financial services industry and a developer of variable insurance products I strongly urge the SEC to repeal 12b-1 fees for variable products. Insurance companies have used 12b-1 fees to bake in their own margin to meet their required ROE. In effect, 12b-1 fees have become a "shell game" for insurance companies and have allowed them to camouflage their profit margin as investment management fees.