October 27, 2010
I have been a licensed insurance professional in several states for 6 years. I am in support of the proposed SEC rule 12b-2. However, I do not believe that allowing broker dealers to create a new share class and create their own fees structure would in the best interest of the general public.
Having been an IT professional for 20 years I made many bad decisions based on advertising of financial companies. Creating another share class and fee structure will further complicate the industry and potentially lead to clients trying to go it alone in the investment landscape.
This would be detrimental to clients as they will largely need to go it alone as I attempted to as a amatuer investor prior to coming into the industry. The advise I provide to my clients is valuable, however I still need to earn a living as well and would find it challenging to service my existing clients if I am constantly seeking new clients to add to my book.
Investors with smaller fund account balances will be forced to self-direct their accounts if they wish to continue to own mutual funds because their advisors will no longer be able to afford to spend the time to guide and advise them, leaving discount brokerage fund platforms as the only affordable option for middle and lower market investors.
Left to their own devices, they will likely trade their investment accounts from emotion, not fact and significantly and negatively effect their investment accounts.
The people the SEC is trying to protect the most--middle and lower market investors—will be hurt the most, since they will be deprived of the guidance and service they need and deserve.