August 17, 2010
I think you should allow C shares to pay a 75 basis point marketing fee for 10 years and then stop. This will keep the choice of C shares as a viable alternative for investors who don't like the committment that payment of a front end commission on A shares represents. It also will mean that brokers will continue to offer C shares.
Your initial proposal to limit the total payable on C shares to the maximum Class A load will effectively remove C shares as an alternative. That approach will force the broker to think in terms of the time value of money. If there is no way for the broker to earn more money with C shares than with A shares, and the broker faces the risk of earning substantially less if the client sells or moves his account, why would that broker ever want to offer C shares to investors? As a practical matter, if your initial proposal is inacted, it will remove C shares from consideration because brokers will downplay class C shares as a choice.