July 29, 2007
To Whom It May Concern:
Please be advised that I am a licensed insurance professional and mutual funds salesman. As a result of providing accessable ongoing service and continuing advice to my clients regarding their investments, I receive trail compensation similiar to renewal commissions on the life insurance policies I sell. This trail compensation is typically paid under a written plan adopted according to SEC Rule 12b-1.
The amount of compensation, similiar to insurance renewals, is very minimal. For example. on a $10K investment in a mutual fund "A" share, the annual "12b-1 fee" that is paid for providing ongoing service equals 25 basis points or $25.
Investors receive a great vale for this charge; they have access to a financial services expert to answer questions and address their specific issues. Without this personal contact investors would have nowhere to seek assistance, with perhaps the exception of a stranger at the end of a little used 800 number. Personal support and contact is imperative and needed and should be compensated.
I am of the opinion that the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. I can, without reservation I believe, state that my clients expect our office to be available to quickly respond to their needs, issues and concerns regarding their investments.
My clients expect me to be compensated for helping them and if the 12b-1 fees were deleted, the client may save a mall amount in 12b-1 fees they would end up paying a much larger amount in other forms of compensation such as hourly fees for asset-based fees to receive the same service.
Concluding, I strongly encourage the SEC to REJECT any proposal or admendment to restrict or eliminate the payment of 12b-1 fees to registered representatives for providing ongoing client specific services.
Thank you in advance for your consideration of my request.
Greg Miller