March 1, 2004
I understand that the SEC Rules 15c2-2 and 15c2-3 referred to as the Point of Sale Disclosure Requirements, will require me to disclose specific mutual fund transaction cost information and potential conflicts of interest that could arise from the distribution of mutual funds. In addition I am advised that the Mutual Fund Reform Act of 2004 could eliminate all 12b-1 fees.
First off, 60 days is not enough time to allow me to digest 100 pages of regulations and to be able to properly allow me to determine how this might affect my business.
Second, if 12b-1 fees are eliminated I will be out of business. In order to stay in business I have to have a way of getting paid. Over the years the 12b-1 fee method has worked out fine. Is it fair, no, I do not really get paid enough now for the services I provide. If registered representives can no longer afford to stay in business the whole industry will crumble. Can you begin to imagine the effect on the economy? I think someone should run some numbers. Think about it: Rent, office personell, office supplies equipment, computers, software, utilities, fees, taxes, printing, advertising, TV, newspapers, travel, conferences will effect hotels, airlines, travel industry, etc.
In my opinion, we are over-regulated now. Its hard to keep up with all that is going on. And yes, people who buy from me know how I get paid and what it cost then. It is all in the prospectuses and I go over it with them. I could go on and on, but I thought these few issues would give those in power a little to think about from someone on the other end of the stick.
Sincerely,
Richard W. Budman