July 19, 2007
I am a Certified Financial Planner(r) practitioner and recommend investments to my clients as a registered representative. Depending on the client's unique circumstances and needs, I recommend (sell) mutual funds, professionally managed accounts or other appropriate financial products. I elect to use a C-share class when recommending mutual fund(s). My compensation is very modest initially and averages between .50% and .90% annually. As a result of the "level" trail generated by the 12b-1 fee, I have a vested interest in helping my client's assets remain steady or grow depending upon their risk profile. Further, I work diligently to select fund(s) which have total expenses (including 12b-1 fees) which compete & often are less expensive than low load or no load funds after an outside management fee is charged to the client. Additionally, I meet regularly with my clients to assess and reevaluate their financial position which results more often than not in a "status quo" stance. Because I receive trail (12b-1) compensation I am pleased to provide this service which I consider an obligation.
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.