November 3, 2010
Dear Sir or Madam,
I have been a licensed insurance professional and registered representative for over 5 years. I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.
However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount. Competition based on price and cost sounds good but will come at the expense of needed advice and service for middle market investors.
This aspect of the proposed rule would have the unintended consequence of hurting the very people you supposedly are trying to help. I have many Clients in the middle market and I provide them with excellent service. I'm not sure what you consider to be "broken" but this 'solution' is off the mark.