July 19, 2007
I am writing to express my concerns about the SEC's ongoing review of Rule 12b-1. I am a Investment Advisor Representative for a mid-size broker dealer as well as a certified financial planner. I am a solo practicioner in the business for 23 years.
Although a third of my client base pays for the ongoing planning and management of their investment portfolios, the remaining two-thirds do not. For these clients, ongoing management is unaffordable, however it cannot be denied that their investment choices are indeed critical to their future in retirement. They came to me in the early years of my practice, and I have a responsibility, indeed obligation, to service their accounts. Many times, especially when it involves some critical issue for them, the process can be extremely time consuming. There is no other way to receive compensation from these people other than the 12-b1 fees, even though it would not qualify for minimum wage when one factors in the amount of time involved to meet their needs.
We all know the common mistakes investors make; buying high and selling low, chasing past performance and harboring unrealistic expectations. 12b-1 fees provide financial advisors with compensation to manage their client's expectations and protect them from falling into this common investor traps.
In conclusion, while it is reasonable to review the investor benefits of 12b-1 fees, it is obvious that the repeal of 12b-1 has the potential to cause great harm to thousands of individual investors who need the support and service of a trained financial advisor. As a result, I urge the SEC to allow Rule 12b-1 to continue to support my efforts to provide needed financial services to middle class American investors pursuing the financial goals.
Marie Coyle, CFP