July 9, 2007
Dear Secretary Morris:
I am a licensed insurance professional, with my CLU, ChFC, IAR, a mutual funds Salesperson, and have been in the business for just over 30 years. My Broker/Dealer is Transamerica Financial Advisors, and they have been my only B/D for over 27++ years.
I am writing you in regard to the "discussions" on the changes or possible elimination of 12b-1 fees.
In order to try and keep my comments brief, I sincerely believe that the services we here in the field provide to our clients, are invaluable. We work with many long term clients who depend on us for good quality service and advice and are more than willing to pay a "small" fee for our work. As for the fee, 25 basis points is truly a small price to pay for the services we provide, and the service our clients have come to expect from us. In many cases, if this 12b-1 fee were not available, many representatives would most probably have to charge a higher fee through "fee for service" or similar fees. Eliminating the 12b-1 fee, in my belief, would end up costing the clients more in the end. On the other hand, I would have no problem with additional disclosure, and/or more disclosure, as I feel my clients do expect me to get paid for the services I provide them, and I feel it's important to them that I continue to do so.
Therefore, more disclosure is NOT a problem, but elimination of the fee would not only reduce the incentives to continue to provide good quality service, but would definitely be to the detriment of the client.
William A. Caplin, CLU, ChFC, IAR