June 13, 2007
As a supervisor for over 200 register representatives/investment advisors, who manage accounts for more than 50,000 households, I am in a unique position to see the benefits of clients being charged 12b-1 fees in their mutual fund accounts.
Because our advisors earn these fees, they are able to adequately service their clients, especially the small account holders. Without these fees, most of our advisors will not want to handle small, under $100,000 accounts, due to the time consuming process of providing service to these accounts. Or they will convert the accounts to Investment Advisory accounts and charge the account holders our standard fees would would average in excess of 1.5%. It is not reasonable to expect a financial advisor who earns his/her living through fees, and commission, to provide service indefinately, just because they paid a commission at the time of purchase.
The net result would be that the very households that need the service/advice most, would either be denied the advice/service of a quality advisor, or they will pay 6 times more in fees. In addition, the mutual fund companies will see a dramatic increase in phone calls, and other related service issues, which in turn will ultimately require them to increase their management fees to adaquately, handle these clients.
Most of my advisors earn less than 20% of their annual revenue from these fees, and spend at least 50% of their time servicing existing clients. These fees have been good for clients, instead of a financial advisor only calling clients to sell them something, they are able to provide service, for the sake of good service.
I urge the commission to not reduce, or eliminate, the 12b-1 fees, as the "Law of Unintended Consequences" will inevitably be invoked. Instead of improving the financial health of the average investor, you will see them suffer because of a lack of service and advice.