July 19, 2007
I am a licensed insurance professional, mutual funds salesperson. I am also licensed as an Investment Advisor Representative and earn advisory fees for my advice.
I strongly believe that my clients are getting a bargain by paying 12b-1 fees in relation to the ongoing services I provide. These include: monitoring their accounts on a monthly basis; rebalancing portfolios, as needed; conducting regular face-to face reviews; keeping them informed on market conditions. With the average portfolio management/wrap fee customarily being charged of 1%-2% ANNUALLY, by a registered rep, the client is paying much more overall (without 12b-1 charges) than the typical 12b-1 fee plus applicable sales charge, over a period of as little as 4 years. You will be doing a diservice to the public if you reduce/eliminate these modest fees, which my clients fee are more than reasonable.
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.