July 19, 2007
I am a licensed insurance professional and mutual funds salesperson.
I am writing in regards to the discussion on 12b-1 fees. I just wanted to point out that no one works for free so please dont make me!
I provide ongoing service and continuing advice to my clients regarding their investments. The amount of this compensation is relatively modest; on a $10,000 investment in a mutual fund's "A" shares, the annual "12b-1 fee" that is paid for providing ongoing service equals 25 basis points, or $25.
My clients receive substantial value for these fees--in exchange for a small annual payment, they have access to a financial services expert to answer their questions and address their concerns. Without their advisor, investors would have nowhere to turn to (except for perhaps a stranger at the end of a 1-800 phone number) when they needed some reassurance in a shaky market or assistance in rebalancing their portfolios, understanding their investments and the investment choices available.
Of course I support full disclosure of all fees. But I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. A significant majority of my clients expect me to be available and to respond quickly to a variety of questions regarding their investments. If 12b-1 fees were eliminated, while my client might save a small amount in 12b-1 fees he or she would end up paying a much larger amount in hourly or asset-based fees in order for me to provide them with the same time & service.
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.
Thank you for your consideration of my views on this subject.