12b-1 feesFrom: Gassan Kassira - Business [Gassan@kassira.com]
Sent: Wednesday, May 05, 2004 5:14 PM
To: rule-comments@sec.gov
Subject: 12b-1 fees (s7-09-04)

I believe it is extremely important to keep 12b-1 fees.  Advisors need to be 
paid for their ongoing support and administration of their client accounts.  
We have to be very careful not to encourage “churning” of accounts or have a 
very short term investment outlook by eliminating the fee. 

If you want to punish for excessive fees than penalize those companies that 
have those excesses.

I personally do not think you have punished or penalized those companies 
(brokerage houses, banks) and the mutual funds that were implicated in the 
recent scandals.  What is a mere $500 Million to them??  They were and have 
been ripping people off for years.  You should be going after them even 
harder!  Today you see the Merrill Lynches and Morgan Stanley’s of the world 
increase their profits by 50% or more.  As if nothing ever happened.  That is 
what is wrong.  How about the frivolous fees they continue to charge in their 
brokerage accounts?  How about the lack of education, credentials and ethics 
commitment by the wirehouse salespeople?   How about changing the laws that 
give banks and an unfair advantage (exemptions) to conduct investment services 
without the proper licensing?

I think you need to change the required credentials for those individuals that 
“sell” or solicit these funds and other investments.  We need a standard that 
investors can rely on for knowledge, commitment and ethics.  I don’t believe 
you should allow just anyone who has passed an exam to sell these products.  
It should be someone accredited.

Changing the fee structures only penalizes the honest for what the dishonest 
have committed.  A “slap on the wrist” to those companies will not suffice!

Please feel free to contact me.

Gassan Kassira

703-569-8363