July 19, 2007
As a financial planner and licensed insurance professional I urge you to reconsider your proposal to cut, reduce or eliminate 12b-1 fees.
A great deal of the public relies on professinal assistance for all or most of their financial and investment decisions. Without adequate assistance, many individuals will be left with little or nothing in the way of retirement dollars, due to poor control over their savings, bad decision making(timing off sales and buys), and lack of confidence in their own financial futures.
In return for providing ongoing service and continuing advice to my clients regarding their investments, I receive trailing compensation much in the same way that insurance agents receive renewal commissions on the life insurance policies they sell. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1. It can add up over many years as we provide continuing service and support for our clients well into their retirement years.
It encourages advisors to keep in touch with their clients and build good strong relationships with them and their children and children's children. This benefits not only the client, agent/advisor/ but also the united states government, by not having to rely so heavily on federal programs like social security and other aid programs for their future security. Thus reducing the burden placed upon the Federal government.
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.