July 31, 2007
Dear Ms. Morris:
I am a financial advisor. I am licensed to sell securities and insurance. Typically, my clients are interested in retirement planning and creating an income stream from their assets to live securely in retirement Many are frugal and have to watch their expenses very carefully. I am in favor of increased, simplified,and understandable disclosure of expenses especially for those who must "watch their pennies."
My practice is based on client-centered planning and 100% of my clients have a written financial plan. I provide ongoing service and continuing advice to my clients regarding their investments. I typically "touch" my clients at least four times a year. For my services, I receive "trailing compensation" on my clients' mutual fund assets like 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.
My clients receive substantial value for these fees. In exchange for a small annual payment, they have access to me as a financial services expert to answer their questions and address their concerns. Without me, these clients would have nowhere to turn to (except for perhaps a 1-800 phone number) when they needed some reassurance in a shaky market or assistance in rebalancing their portfolios, understanding their investments and the investment choices available. Just last week when the market dropped so drastically (immediately after hitting 14000 for a brief period) I had to remind several clients of their long-term, disciplined, modern portfolio-based investment strategy. If I do not provide the support they need, some of my clients would liquidate on market downturns out of fear and seek a 100% fixed portfolio. It takes a long time for me to educate my clients not to make the same mistake their parents made trying to "live off the interest" of their assets in retirement. Too many of their parents outlived their resources. I don't want any of my clients to find themselves at say age 90 living on only meager social security and the generosity of others.
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 my 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 clients might save a small amount in 12b-1 fees they would end up paying more in hourly, annual or asset-based fees for the same service.
For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees for continued service. I support increased, simplified, and understandable disclosure to clients, to help them "watch their pennies."
Thanks for your consideration.
Howard L. Bregman, Ph.D., CRPC®
Ameriprise Financial Services, Inc.