November 4, 2010
In reference to S7-15-10
I have been an investment advisor representative for over 5 years now and I commend the increased transparency of 12b-1 fees that the SEC is proposing. I have long felt that these fees were very misleading and seldomly explained well to our clients.
However, in the attempt to assist the consumer, I believe the new proposed n.a.v. class of shares will actually harm the average investor. While "price competition" sounds good on the surface, I believe this approach will cause broker dealers to undercut one another in an attempt to gain market share. This will lead to a transaction based approach to investing and cause bd's to only be concerned about more and more volume at the expense of service.
So what will start out as an effort to protect the "little guy" will end up with only the more wealthy investors who can afford to pay higher fees for better services benefitting. Meanwhile, the "mainstreet" investor will be left w/ no ongoing service as we as registered reps will no longer be able to afford to give them the ongoing assistance we once did. I strongly urge you to abandon this part of the proposed changes as it will not have the desired affect you are looking for.
Joshua R. Sirek