Subject: File Number S7-15-10
October 27, 2010
I understand that the SEC is considering allowing Broker Dealers to set their own sales charges and commission structures.
While I don't know all of the implications to this change, here is one of my concerns:
1. This will overly complicate the process.
a. Today, it doesn't take a lot of time or material to explain an A Share vs a C Share.
b. The FINRA comparison tool is excellent in helping to communicate the impact of the two shares
2. For example: I receive a phone call from someone who wants to know, "What do you charge for xyz fund?" Because after all, it's the same fund, whether he buys it from me or the next rep on his call list.
c. With every B/D setting their sales charges and commission structures, the buyer of these funds will have to do MORE research, not less, in order to decide on the best deal for themselves
i. I recently compared prices for computers. You would think a quick comparison between a Dell Laptop and an HP with x amount of memory, chip, OS and hard drive would be fairly straight forward.
1. But, it is the hidden cost of installation and maintenance that has the greatest impact, the so called "Total Cost of Ownership". These expenses occur AFTER the sale.
a. Let's say I have the lowest cost and he decides to purchase the fund through me, BASED ON THE INITIAL COST OF THE PLAN.
i. Later he comes in to the office and wants expanded services or advice, which I will then want to charge for, or if I don't have the proper licensing, refuse the service.
ii. Unfortunately for him, if he had bought the xyz fund from the other, more expensive broker, he may have gotten these follow up services included.
Whatever you do, please, please, keep it simple. Investors and investment advisors are overwhelmed with regulations that complicate the process.
If your outcome is to help the majority of investors, do not create a system where every B/D in America has a different or potentially different sales charge.
"Almost all quality improvement comes via simplification of design, manufacturing... layout, processes, and procedures. "
Edwin A. McKnight, LUTCF
Investment Advisor Representative
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