July 9, 2007
Dear Ms. Morris:
I am interested in the recent questions that have arose in the SEC regarding "12b-1" fee. As a licensed financial planner who has clients with mutual funds it is an interesting discussion. I prefer to work with my clients through an ongoing, collaborative, financial planning relationship. I help my clients identify dreams, create a plan to get them there, and track their progress along the way.
I also have clients that prefer to not pay a fee for my advice and just want to discuss transactions on their investments. I serve my clients every single year, whether they pay a fee or merely have $10,000 in mutual funds. If they choose to not respond to our meeting requests, we proactively review their accounts and send a follow up letter if necessary.
In contrast, they might have an insurance agent that went knocking door to door 10 years ago and sold them a life policy and has not seen or contacted them since, he receives renewal premiums and provides less value than my team. It doesn't seem to make sense that renewal premiums are legitimate, but 12b-1's are under review.
While I don't depend on 12b-1 fees to run my practice, I and my team would be unable to continue to serve the approximate 300 clients that do not have an advice relationship with me. We currently have a handful of clients that generate zero revenue. I continue to serve them out of respect for their loyalty to the company. Unfortunately, the economics of 300 clients in that situation would necessitate a negative change in my policies. At that point I could not afford to continue to see clients that do not pay an advisory fee and they would need to call a 1-800 number for service. I and they would have a hard time with that reality, as well as the fact that my minimum financial planning fee based on my years of experience, designations, and complexity of client situations is a minimum of $350.00. There are clients that would not receive $350 of value for what they are requesting.
For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients. I would support a measure renaming and explanding the purpose of 12b-1 fees for greater transparency, because I do agree that the original intent has changed. Thank you for your consideration of my views on this subject.
Kimberly Madsen, AAMS, CRPC
Senior Financial Advisor
An Ameriprise Platinum Financial Services practice