July 19, 2007
I am a licensed insurance professional and mutual funds salesperson. I have been in business since 1975. My educational background is a Master of Science in Metallurgical Engineering. I have achieved 3 professional designations from the American College.
In return for providing ongoing service and continuing advice to my clients regarding their investments. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1. We disclose that we will recieve this revenue at the time of sale and at our client reviews.
The amount of this compensation is 25 basis points, 0.0025 of the amount we manage. Investors receive substantial value for these fees that they have agreed to pay.
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.