August 25, 2010
I am writing to comment on the proposed changes to rule 12b-1, specifically as they pertain to class C shares of funds.
As an experienced advisor with more than 200 clients and over a quarter century experience, I pride myself on doing what is in the best interest of my clients. That is why I believe the current proposal to limit the class C ongoing fees will be harmful, not helpful to my clients.
Wherever appropriate I try to put clients in a good family of funds, in A shares. However, in order to achieve maximum diversification and non-correlation, I try to round out a client`s portfolio with class C shares of successful funds in certain sectors. Overall this gives the client the best possible allocation at the least cost. If the ongoing fees are dropped, I fear that the whole push in our industry is toward charging clients an ongoing asset management fee. For my clients, who are mostly buy and hold, long term investors with a large chunk of their asssets in individual fixed income securities.they are much better off under the old system of "pay as you go" commissions, rather than paying an ongoing fee.
As with all federal regulations, I hope you will seriously consider the unintended consequences BEFORE enacting new rules that will hurt clients
and those of us dedicted to serving them!