July 19, 2007
I am a licensed insurance agent and offer mutual fund investments for families as well.
Under Rule 12b-1 I receive trail compensation from investment companies based on assets under management. The amount of 12b-1 compensation is relativley small and I think adds tremendous value to my clients.
The elimination of rule 12b-1 would have a negative impact on clients and those who want and seek out counsel in making good money decisions. Clients want to be able to work with someone easily and with out necessarily having to pay a separate fee every time they call or meet their advisor. Rule 12b-1 allows us as investment professionals to be available much more easily and in many cases be more affordable for our clients. With out this trail compensation, clients would be forced to pay higher fees to their advisors and this may disuade many from seeking out professional help, and potentially making grave mistakes with their investments. Just as I receive renewal comp on insurance policies for continued service, I receive trail comp on investments for continued 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.