July 10, 2007
To whom it may concern - Concerning the consideration to cut back or stop 12B-1 fees:
To try to make it brief, I have been a registered representative since the early 80's. At those times, we only had Class A shares basically, with what I considered high up front charges. I discussed this more than once with my broker-dealer, saying that I thought we needed to cut back on the up front load and possibly pay a little more in the way of fees to help one better service existing customers, because as your customer base grew, it did give you a larger business clientele to do business with, but, in many cases, that clientele had limited resources for investments, but you tried to service all of your clients in a like manner, regardless of the size of investment.
Of course as this clientele grew, your expenses and time spent on the sources became greater and greater, and in some cases took much time away from going out and actively seeking new clients.
We have helped solve the cost problem by lowering the cost to get into A shares and with the creation of B and C shares. However, if there is a problem out there, where I see it, is where a fee based registered representative puts people in C shares who have a long investment horizon. If you read NASD information, it will tell you when A, B and C shares should be applied and C shares should be applied where we have a short horizon period as the ongoing cost is greater with C shares than A or B shares. I feel some fee based planners who are charging a fee for financial guidance are putting clients into C shares and also collecting trails on that, when a client would have been better served in a different share class.
Jack E. Tosetti