From: Michelle Dixon |
I am writing in response to the request for comments on Rule 12b-1. As an interested party, being involved in both insurance and mutual fund sales, I would be more than willing to discuss the topic. I DO absolutely support the continued payment of 12b-1 fees. I also support full disclosure of fees and expenses to investors, as I always have. I do not believe that the use of these fees has been altered from their original purpose, of assisting with the growth of mutual funds. It also affords an opportunity for registered representatives to have an active interest in the performance of their clients' mutual fund investments. I provide ongoing service to not only my clients, but "adopt" those clients who no longer have a representative, but still need service. My only compensation for servicing those clients who have an established mutual fund account, but are no longer contributing to it, is the modest amount afforded by the 12b-1 fees. I don't believe, and more importantly, I don't think the shareholders believe that I should be expected to service their accounts without compensation. As for disclosure, I have always supported and practiced full disclosure to my investors. I believe that every investor should be fully informed, although I must admit that I don't think many of them retain much of that information. That is primarily why they are in need of the services of a professional. This simply furthers the concept of the continuance of 12b-1 fees. Life experience dictates that professional services are most often accompanied by professional fees. If those fees are not to be funded by the 12b-1 Rule, then what alternative measures are being discussed? I am unaware of any proposed alternatives that would not be detrimental to the investors themselves. Therefore, I do believe that the original purpose of 12b-1 fees are still being served by assisting with the growth and continuity of mutual funds, and must urge the SEC to reject any proposal restricting the payment of 12b-1 fees to registered representatives for providing ongoing service to their clients. Thank you for your consideration in this matter. Michelle Dixon |