July 30, 2007
Dear Ms. Morris:
I am a licensed financial advisor with Ameriprise Financial. During the course of my duties I offer financial planning advice and investments such as insurance and mutual fund products.
In return for providing ongoing service and continuing advice to my clients regarding their mutual fund investments, I receive trailing compensation much in the same way that insurance agents receive renewal commissions on the life insurance policies they sell. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1.
The amount of this compensation is relatively modest; on a $10,000 investment in a mutual fund's "A" shares, the annual "12b-1 fee" that is paid for providing ongoing service equals 25 basis points, or $25. Investors DO receive substantial value for this fee.
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. I can tell you that if 12b-1 fees are eliminated I will personally have to stop servicing some 100 plus clients as it is not in my interest to provide ongoing advice without compensation. Providing this advice would only put myself in harms way of potential lawsuits and additional work should the market turn south. A significant majority of my clients expect our office to be available and to respond quickly to a variety of questions regarding their investments especially when they need some reassurance in a shaky market, assistance in rebalancing their portfolios, understanding their investments and investment choices, etc. And as a respected advisor it is my duty to provide this advice even though I may not get any compensation (i.e. additional sales charges). If the advice is to stay within the same family of funds but to diversify within those funds we as advisors receive NO compensation for this advice. This is why, I believe, we are compensated with 12b-1 fees (to allow us to do what is right for the client).
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. Thank you for your consideration of my views on this subject.
The finest compliment that we can ever receive is a referral from our clients. Working primarily by referral means that we can focus more time on all of your financial goals. With that in mind, please do not keep us a secret.
Richard C. Osman, CFP®, CLU™, ChFC®, CASL Financial Advisor | CERTIFIED FINANCIAL PLANNER™ practitioner