October 27, 2010
This email is in reference to the proposed SEC rules for 12B 1 fees and allowing b/d's and reps to set their own commission scale based on the level of service they provide and the competitive environment. I have been a financial rep both as an insurance representative and a registered rep for almost 15 years. I am a CFP® as well as a CLU. I have no problem with improving the transparency of the 12B-1 fees, yet allowing a 25 BP trail to continue. I do however STRONGLY oppose the SEC permitting mutual funds to issue the new share class at NAV, allowing B/D's to set their own sales charge and commission amounts.
This change may be well intended, but the unintended consequence would be a sprint to the bottom making it impossible to provide sales or service for small and mid-sized accounts. Managing poor investor behavior is already one of our biggest challenges, I can't imagine trying to do it with virtually a wholesale pricing model. In my opinion, quality of advice and service will go down, damaging the long term viability of the average investor. Please reconsider this portion of the proposed SEC ruling.
Thanks for your consideration,