August 24, 2010
I service individual clients, as well as small business and their retirement accounts for their employees.
I am vehemently oppossed to the 12(b)1 changes which have been suggested. I use "C" share classes mainly for my clients investments as the fee based payment structure allows the client flexibility, removes commission based conflicts of interests, and allows me to work with smaller clients who might not otherwise be able to service.
If these suggested changes are put in place, then I will have to drastically change my business model, fire some smaller clients, thus harming them from a loss of advice, and I will have to discuss selling out entire client accounts in order to switch them to a wrap account, which functions essentially as "C" shares, causing the clients undo and unneccessary capital gains.
I understand that 12(b)1 fees are not being used as originally intended, but today's investing world has changed and it requires more frequent and constant monitoring of portfolios. Clients do not buy and hold things for 20 years like they used to. C shares with their 12(b)1 fees allow advisors to work on a continuing basis with clients for hopefully the duaration of their lifetime.
I strongly urge against making these proposed changes as it will harm the consumer in the long-run. I am in favor of greater transparency and I have always been upfront with informing my clients of ALL costs including 12(b)1 fees.
Please do not change the current structure of C shares.
Brad Foy, CFP