November 3, 2010
I have been a registered rep for over 10 years, and 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 will end up encouraging retail price competition, which will have a very negative impact on the consumer. The middle income consumer will be the one to suffer because the clients will not be taken care of appropriately.
Thank you for your time and cooperation.