August 31, 2010
I agree with the fact that measures should be taken to improve the regulation of mutual fund fees and to provide better disclosure to investors. However, I do not agree with the proposal as it currently stands. With all of the changes going on in our country over the last couple of years, I do not believe a reinvention of the wheel is warranted in this situation.
These fees should be better disclosed to clients. I agree that 12b-1 fees should appear on transaction confirmations. Let's face it, many individuals are not going to read the prospectus for a fund and if they do, they still may not completely understand how the charge works and/or is reflected in their account. Spelling it out in plain English, as has been done recently with the summarized prospectus, makes sense.
My biggest issue with the current proposal is the limitation of the sales charges and here is why. My wife and I are in our late 20's. We're just starting out, but we are planning for our future. As our accounts are small, my fear is that we will not be able to receive the same professional service as we have over the last 3 years if the ongoing sales charges or front-load charges are restricted or eliminated. What motivation is there for a representative to take on my account with the size it currently is if their not going to receive an ongoing charge? I work hard because I get paid NOT because I like to work and I believe that is true about everyone in this country to some degree. I believe that by reducing or eliminating these charges, you are greatly reducing the number of professionals that will work with me and millions of others in my same situation. Individuals already have a choice. No-load funds already exist and everyone has the ability to use them should they not want to receive the same professional assistance they may receive when using a load-bearing fund. Perhaps a good idea would be to encourage more funds to offer a no-load option. You could call it an N-Share.
In conclusion, it is my belief that you should not reinvent the wheel, but that some tweaks should be made. Making the fees more apparent to the potential investor is important because they will be able to better make their decision between a no-load or a load-bearing fund. I also believe that eliminating or reducing these fees will greatly inhibit my ability to work with certain professionals in this industry. Instead of increasing competition, it will greatly decrease the availability of firms that will work with millions of Americans that are starting out.
A concerned investor