August 9, 2010
My comments are geared towards the belief that all investors (especially my clients) should have options of how they want to be charged for the planning services that we offer. I totally agree that there needs to be better disclosure for investors. Now, take into account the area where I am from Flint, Michigan. A large portion of my clients do not have the asset base to even qualify for a Fee-Based wrap/institutional investment platform. That is where the C share has allowed them the capability to have a well diversified, professionally managed portfolio with access to the best money managers in existence. If you limit my pay as an advisor then I will end up telling these clients too bad you need to go to E Trade because I am not going to be able to spend my time managing your assets that are in line with the Asset allocation Plan that we created to sync with the Retirement Plan Analysis we annually sit down to make sure you are in line with. How does this help a client/any investor? It doesn't. If you are looking into changing C shares then you would have to consider changing Class B Class A shares. It takes anywhere from 6-8 years for a Class A to breakeven with the expense ratio of a Class C Fund. You are going to promote churning by forcing advisors to liquidate a Class C share Fund every 4-6 years just so that advisors can get paid. Honestly, no matter how well the fund did if it was coming up on the anniversary where the trail would be reduced to 0.25% most advisors (more than not) will most likely sell that fund with the money possibly reinvested into a less superior performer with possibly more risk. With these transactions taking place, can you imagine the # of advisors that will do the same thing in order to get paid which will essentially raise operational costs for the fund companies which ultimately gets passed down to the investors. Also, you must figure in the cost for the increased disclosure requirements that will inevitably force fund companies to track how sales charges get paid on an individual level. Again these costs trickle down to the shareholders. This means that all this proposal has accomplished is nothing.