August 19, 2010
Dear Ms. Murphy:
While it is clear there is a need for clarity and transparency of fees paid by retail investors, I urge the SEC to consider the impact on small retail investors of strict curtailment of 12(b)1 fees. In order for financial planners or financial services representatives to be able to provide service to small accounts, some means of ongoing service fee must be allowed. The result of the proposed cap at 25 basis points is likely to be the wholesale abandonment by financial advisors of smaller accounts (Individual IRAs, 529 plans, and starter accounts for young investors) due to the impossibility of providing uncompensated service. This would remove access to advice of a financial professional from precisely that category of investor that the proposed rules presumably wish to assist. The objective of the rules might be better achieved through a more direct and simplified disclosure requirement rather than elimination or drastic reduction in the fees themselves.
Mr. Terry R. Altman
Certified Financial Planner(r)
Altman Financial LLC