From: Lyn Quarantello [lynq@frontiernet.net]
Sent: Friday, May 07, 2004 10:53 AM
To: rule-comments@sec.gov
Subject: S7-09-04

To:  Jonathan G. Katz Secretary U.S. SEC

 

I wish to express my concern about the proposal to eliminate 12b-1 fees under 
the Investment Company Act of 1940.  As an independent financial advisor and 
Certified Financial Planner these small fees allow me to continue to serve my 
clients who have no new monies to invest long after the initial sale.  As an 
example, I have an elderly couple who live 50 miles from my office - they 
invested through me in 1994.  They are not able to travel so I travel to them.  
I help them with understanding the paperwork they receive and assorted other 
issues concerning their investments.  All this paperwork, qualified and 
non-qualified accounts etc., can be overwhelming for people in their late 70’s 
and early 80’s.  This is also a generation that is loath to pay fees for 
anything even when they need help.  Having the fees built into the assets 
under management allows me to work for them without having to look for another 
way to get paid.  We would do a great disservice to all clients who need help 
if they had to be charged each and every time they need assistance; they just 
would not pay for it.  While the 12b-l fees are not each individually enough 
to pay for my time when there are enough assets under management it does allow 
for what would otherwise have to be pro bono work.  It is work that would not 
get done by many in the industry if they are not being paid for it.  We in the 
industry would not suffer because we could adapt by just selling and moving on 
to the next one – it is our clients that would suffer.  There are enough 
people in this industry that churn and burn; the SEC should not 
institutionalize that mentality.  

 

Lyn Quarantello, CFP

Series 6, 7, 22, 24, 51, 63, 65

Insurance licensed NYS