July 19, 2007
I am a licensed insurance professional and mutual funds salesperson.
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 seems that more and more of our customers are coming to us for financial advice on many different matters. It used to be said that the internet would elimate alot of people in our profession. As things have turned out it seems that our customers want to talk to and learn from us re: their financial plans. The 12b-1 fees are very fair for the clients. Most clients that I service want to know how I'm paid, and they agree that we should be compensated for providing lifelong service. The thing to remember is that the more efficiently we serve our client the more the client may benefit. 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. 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.