August 14, 2007
Dear Ms. Morris,
I am dually lincensed in both the insurance and securities industry.
This is two entities that requires service not only periodically, but also be available at the any time the client requests it. Without this availablility, most people would feel that they are being deserted when they need assistance from their representative. For this "hands on" service, I receive a small compensation in the form of trailing fees, much like I receive renewal fees on the life insurance policies I sell. This trailing fee is typically paid under a written plan adopted pursuant to SEC Rule 12b-1.
The amount of this compensation is very modest. On a $10,000 invest in a Class A mutual fund, I am only paid 1/4 of 1%. For this small compensation, the investors receive substantial value for these fees. They have ready assess to their representative for all types of assistance, such as questions, maintenance, and periodic reviews. Since most investors in mutual funds are not educated in the field of finance, they depend heavily on their representative for assistance and reassurance.
I believe the elimination of 12b-1 fees would do considerable harm to the vast majority of first time investors. My clients expect me to be available and to respond quickly to all calls. They expect me to help them reach their long-term financial goals. I have never received a complaint from a client concerning this fee. My clients expect me to be compensated for my services. The one complaint I do hear is that they do not receive service from other companies. Granted, if 12b-1 were eliminated my clients would save a small amount, but they would pay much greater amount for services on an "as needs" basis.
For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 to registered reprentations for providing continued service to their clients. Thank you for your consideration of my views on this subject.
Patricia H. Bevis