September 15, 2010
The 12(b)1 issue is misdirected. It should only be focused on more obvious disclosure, since the C share fees are no higher then most fee-based costs, the only real issue is do the clients realize their investments are paying this amount?
Our average clients assets are $150,000. When you compare the cost charts for A, B(all but dead by now) and C shares, the costs are close. A shares are better if held for more than 6 year; C shares are better up to that point. C shares eliminate "churning" of accounts. But even at 10 years or whatever (not that clients really know how long their investments are going to be there) the difference is account value is MOSTLY determined by the choice of 1) investment options, like growth, value, large cap, stock, bond, etc. and then by 2) manager and/or mutual fund group. The difference in total fees between A shares and C shares are at best third in priority — trivial.
Focus the changes on transparency and disclosure. If I move all my clients to fee-based, they will pay more than they do now. If the only issue was fees, everyone should do no-loads and get no advice.
Finally, if you make the change as recommended, there would rarely ever be a situation appropriate to use A shares --- they should be eliminated. Nothing would ever be better than C shares or fee-based.