October 28, 2010
Dear SEC:
I have been a licensed insurance agent and registered rep for over 26 years. I fully support SEC rule 12b-2. This rule allows me to continue to provide service and advice to all of my investor clients. I also like the SEC's terminology "Marketing and Servicing Fees" in lieu of "12b-1 Fees". This improves transparency and is more understandable to my clients.
I also, however, object to the SEC permitting mutual funds to issue a new class of shares that allow broker dealers to set their own sales charge/ commission amount. This idea sounds good on the front end but in the long term will force registered reps to neglect investors with smaller fund account balances. As broker dealers lower their sales charges and fees in an effort to gain market share it will force all of us to seek only the upper income investors with larger amounts of assets to manage. The people the SEC is trying to protect the most (middle and lower market investors) will actually be hurt the most since they will be deprived of the advice and service they need.
I appreciate your attention and consideration of this matter.
Thank you,
Jeff L. Holland, CLU, ChFC
HollandStivers & Associates, LLC