March 9, 2004
I have been a member of the NASD for almost 19 years.
In that time, I have ALWAYS provided full disclosure to my clients regarding options and costs they incur.
I have NEVER avoided providing my clients with Break Point discounts where available and feasible.
For my clients whom the best alternative is mutual fund A shares, and they have concurred, they desire ongoing monitoring and continued access to my expertise.
The ONLY compensation I receive from this labor intensive activity is the SMALL amount of 12b-1 fees provided to me.
By relinquishing these fees, you will effectively be sanctioning professionals like myself to become product pushers, with no ongoing assistance that these consumers so desperately need and value.
These 12b-1 fees are minimal and my clients deserve the opportunity to allow them in return for the proportionally HUGE amount of service they afford.
I urge you not to mandate the removal of such fees.
Furthermore, due to the length of the context of your rule proposals, it would not be frivolous for you to extend the comment period an additional 60 days.
Charles B. Milliken, CFP
Mutual Service Corporation