August 20, 2010
Here is a suggestion that I'm sure you have heard:
All 12b-1s should be disclosed quarterly, similar to a debit notice sent to the client from the fee based adviser.
12b-1s are not bad, they should be disclosed better.
A small group of fee based advisers that manage high net worth clients' money look at this and complain that it's not fair to the client. The fact is these same adviser will not work with the smaller clients because they don't have enough money. The smaller client will get hurt by taking away 12b-1s or limiting 12b-1s to .25bps.
Please leave the 12b-1 the same, but create a system to disclose the fees. Fund companies can disclose the 12b-1s quarterly to clients and advisers can disclose the fee at the time of the investment.
If 12b-1s are limited to .25bps, the cost to the smaller investor will increase. I can see advisers charging hourly fees for advice since they would not receive 12b-1s. most smaller investors will not pay for this and therefore redeem their shares. (look at the holding periods of mutual funds without reps and look at the holding periods for funds that have reps. Funds that are held by clients that have advisers will hold the funds longer)
Thank you for taking the time to read my comment.