July 19, 2007
I am a licensed insurance professional and registered representative and have been requested to comment regarding 12b-1 fees and their proposed elimination.
Allow me to suggest that you reconsdier your viewpoint and look at what the consumer is receiving in return for the professional advice from an individual who is properly licensed to serve them.
25 basis points is very small in return for that advice and counsel afforded so many clients. While you have had the example of a $10,000 investment, allow me to suggest a $500,000 account. Accordingly the fee would be $1250 annually of which the representaive would recieve a portion depending upon his/her broker dealer's payout structure. Now, assume I recieve 50% of the fee or $625. My time is worth approximately $250 per hour if it were billed on an hourly basis. This equates to approximatley 2.5 hours of my time whereby I would be compensated.
I would venture that I spend far more of my time on that account than 2.5 hours in meeting with the client, addressing concerns and making the appropriuate adjustments. This doesn't take into consideration the time invested handling client inquiries and questions. Where is the incentive to address the client's needs and concerns. Ms. Morris, I doubt yoiu work for free. Therefore, I recommend that you not request the many capable advsiors and representatives be requested to do so.
Further, what will transpire in your secenario is projectedly that the client or as you call them the "consumer" will receive less service and attention. It will be a self defeating proficy. You will be hurting most those that you were attempting to help.
Moreover the consumer has benefited over the last years because sales charges have declined. Please refer to a prospectus of the early '80s. I think you will find the shareholders are paying far less up front than ever before.
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 our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the small amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. If 12b-1 fees were eliminated, while the 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 to receive the same 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.