July 19, 2007
I am an independent financial professional and began my career in 1975. I quickly realized that competitive products alone would not separate me from the hundreds of others offering financial services. Therefor, I have worked diligently over the years to obtain certification as a CLU, ChFC, Licensed Insurance Advisor, and Registered Representative The success of my practice has hinged on personal service and my ability to offer clients the expertise of such education. This advice and service is ongoing, usually without charge, and has come to be expected by my clientele. This value is a major reason why they refer me to those they care about.
It is understood [by my clients] that I need to be compensated for my services. Investment fees, referred to as 12b-1 fees, provide a modest income which helps to compensate me for the continued education which supports this level of customer service. The alternative would be numerous "800" calls to multiple investment companies, calls likely fielded by strangers who don't know my client's personal situation and are often improperly educated and poorly trained. My clients would not appreciate this!
On the other hand, I firmly beleive that an educated and informed consumer is the best client. Full disclosure regarding fees and commissions should be mandatory! Such transparency builds confidence, eliminates suprises and gives the financial practicioner the ability to show the client the true value of his/her service! If given the choice bewteen 12b-1 fees or an hourly fee, I know my clients would opt for the 12b-1 fees. They would certainly be lower.
I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients.
Thank you for your consideration of my views on this subject.