September 28, 2010
I submit to the SEC that 12b-1 fees should not be eliminated because of the on going service work that the large majority of registered representatives do to aid and advise the clients of those funds. The average investor knows nothing about their investments. All they know is that the investments help in the long term growth of their net worth and that their advisor will provide guidance in growing the clints assets.
Resently, the broker advisor has been in the news a lot due to mal-practice of their professional duties. However, that only represents a small percentage of advisors who abuse their right to practice their trade. By and large the average RIA, Registered Rep, and Financial Advisor, practice within the moral and practical applications set forth by the SEC and FINRA organizations so as not to step out of bounds or create a situation that could end up being liable. Hence, the reg rep's are entitled to the 12b-1 fees as part of their on going pay structure.
Is there disclosure and transparency? My answer is yes. I know that I disclose all fees, whether asked or not. The people I do business with have no problem with me earning my pay scale so to speak so long as there is continual contact going on after the sale. And of course, they have the opportunity to make head way on their returns within their funds. I have found that communication is key to helping my clients understand what they own. Removing the 12b-1 fees would only make it harder for me and others like me to build a practice if I am forced into replacing funds needlesly. By keeping our fee structure in tact we are able to operate as we were once taught by the organization who also dictates policy. YOU
Keep the fees. They are not a threat to compitition or to the growth of the funds in the market place. They are an incentive to do the right thing for the client.