From: H. Michael Finkle
During your deliberations over the future of 12-b1 fees take into consideration what these fees really cover. They are simply client servicing fees, period. As a 40 year veteran of the investment industry I can tell you that our average return on assets has steadily declined over the years as we do more and more mutual fund business and we are perfectly happy with that situation. Over a period of years we essentially receive 25 bps to service, research, reallocate and advise clients who own funds. It is a great deal for the client and cheaper than any other pricing platform alternative we have available.
We compensate by simply getting more assets under management to earn the same income we used to earn in a transaction based relationship with much smaller assets.
You might be able to justify changing what the fee is called or designated to pay for but I see not justification to reduce or eliminate 12b-1 fees.
Thanks for your consideration.
H. Michael Finkle