From: David J. Lutz Jr. |
Nancy M. Morris, Secretary Dear Ms. Morris: I am a licensed insurance professional and mutual funds salesperson. Since I am relatively new to the financial services industry, most of my clients are young with little money to invest. As such, many times and only after careful individual meetings, do I recommend a mutual fund typically with a front end sales load. I believe this type of payment arrangement for my services is best for the client as compared to an annual 1% fee or hourly charge. In return for this type of payment agreement, I meet with my clients once a year of which I charge them nothing for my time mainly due to the fact that I am receiving ongoing compensation in the form of 12b-1 fees. 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. I can understand the SEC is in charge of protecting the investing public. If I was a normal investor I would not know what a 12b-1 fee was. Thus, if the SEC is really looking for a solution, why not rename the fee as what it really is, namely an “ongoing service fee”. I’m sure the investing public would understand this as it is simple and is not trying to hide a fee behind letters and numbers. Thank you for your consideration of my views on this subject. If you need to reach me for any reason to verify this information I can be reached at (412) 539-0055 or lutz@advisorsgroup-pgh.com. Sincerely, David J. Lutz Jr. |