November 5, 2010
I have been a licensed insurance professional and registered representative for over 26 years.
I believe that the elements of proposed SEC rule 12b-2, which would continue to the 25 basis points fee for ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge will improve transparency. However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount.
Consumers currently have many options the financial services market. I am deeply concerned that allowing broker dealers to effectively set their own sales charges and fees could create greater confusion and potentially decrease the level of service afforded to the people who need it most like the majority of my educator client demographic.
The people the SEC is trying to protect the most--middle and lower market investors—will be hurt the most, since they will be deprived of the guidance and service they need and deserve.