From: Barry Phillips
I am writing to express my concerns about the SEC's ongoing review of Rule 12b-1. Middle class Americans need the continuing service, guidance and support that are provided by independent financial advisors to achieve their stated investment goals. 12b-1 fees provide a tax efficient means to support the CONTINUING SERVICE which these clients require for successful investing. The benefits of 12b-1 fees are numerous and include:
.Expanding Investor Choice - The multiple share classes made possible by Rule 12b-1 give investors choices by providing them with options in how they pay their financial advisor. The flexibility offered by Rule 12b-1 allows financial advisors to tailor a portfolio to their client's specific needs.
.Supporting Financial Literacy - Mutual funds send their investors monthly statements, confirmations, prospectuses, annual reports, and other materials. Financial advisors serve the vital role of educators by helping investors to make sense of these essential materials. 12b-1 fees are the compensation financial advisors receive for these efforts.
.Managing Client Expectations - 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.
.Insuring Small Accounts Receive Service - Investment advisory services are simply out of the reach of many small account holders. Financial advisors must have another means of being fairly compensated for servicing these accounts. 12b-1 fees provide the mechanism to insure small investors receive the support and service they need to achieve their financial goals.
.Subsidizing Additional Services - Independent financial advisors offer their mutual fund clients a variety of additional services including: consolidated account statements, periodic portfolio review meetings, quarterly newsletters, cost basis research, preparation of tax returns, and consulting on other financial decisions. These important services are made possible by the subsidy 12b-1 fees provide.
In conclusion, while it is reasonable to review the investor benefits of 12b-1 fees, it is obvious that the repeal of 12b-1 WILL CAUSE great harm to thousands of individual investors who NEED ADVICE AND THE SUPPORT AND GUIDENCE 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. MY GREATEST FEAR IS THAT WITHOUT 12b-1 FEES, TRAINED ADVISORS WILL HAVE TO CUT DOWN, OR EVEN DROP THE CLIENT BECAUSE THEY MUST MAKE SOME ONGOING COMPENSATION NOT FROM THE CLIENT,[ BECAUSE SOME CLIENTS WILL NOT PAY]BUT FROM THE INVESTMENT COMPANY IN ORDER TO RETAIN PROPER CLIENT SERVICE. IN ESSENCE, CHANGING THE 12b-1 STUCTURE, WILL LEAVE THE SMALL/MIDDLE CLASS INVESTORS TO, "DO-IT-YOURSELF INVESTING" BECAUSE THEY CANNOT PAY FOR THE; MORTGAGE,FOOD,SCHOOL, CLOTHING, FARES TO AND BACK FROM WORK AND NOW............PAY FEES THAT THEY NEVER HAVE BEFORE?????. PROBABLE RESULT-----MORE PEOPLE ON WELFARE IN FUTURE YEARS!!. THE SEC SHOULD HELP PROTECT THE "WORKING FAMILIES", NOT HURT THEM BY ADDING TO THE MONTHLY BUDGET THAT IS ALREADY STRETCHED TO THE LIMIT!!. CHANGES IN THE 12b-1'S STUCTURE WILL HURT MANY MORE THAN IT WILL HELP. IN SUMMARY, THE USE OF 12b-1 FEES IS NEEDED NOW MORE THAN IN THE 1980'S WHEN MONEY MARKETS WERE PAYING 16%-18%, WITHOUT ANY RISK!!. PEOPLE NEED FINANCIAL HELP---DON'T PRICE THEM OUT OF THE MARKET, AS SO MANY FAMILIES ARE NOW LIVING PAYCHECK-TO-PAYCHECK. THE SEC SHOULD HELP INVESTORS CUT THE COST OF LIVING, NOT ADD FEES THAT MANY CAN'T AFFORD!!. WHAT'S NEXT....DO-IT-YOURSELF ROOT CANAL????.
Sincerely, BARRY A. PHILLIPS, REGISTERED REPRESENTATIVE
MR BARRY PHILLIPS