July 19, 2007
As a financial professional, I am compelled to write and voice my concerns about the possible elimination of 12b-1 fees. As a financial advisor, I do a careful interview with all my clients and assess their financial goals and help them put together a portfolio to meet their financial goas and objectives. We discuss their risk tolerance and timeline and develop a customized plan for them which might include mutual fund recommendations. I continue to monitor their financial plan and together with the client, make adjustments as needed (ie as their timeline and/or risk tolerance) changes.
I disclose to all my clients what my renumeration will be and that includes making them aware of the part of 12b-1 fees that I receive for keeping their portfolio in line with their goals. Eliminating these fees means that the financial professional has no incentive to monitor client mutual funds to be sure they are still meeting the clients' needs and objectives.
As a financial professional, I cannot work for no compensation. If I cannot provide cleints with ongoing monitoring of their portfolio, they will not have a professioanl who understand their individual needs and concerns. Thre would be no one for them to talk to during down markets or up markets, who will advise them of the best course to take with their mutual fund portfolios. The most they could hope for would be an invisible contact through an 800 number who does not know the client or his goals and objevtives.
I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. A significant majority of my clients expect our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the small amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. If 12b-1 fees were eliminated, while the client might save a small amount in 12b-1 fees he or she would end up paying a much larger amount in hourly or asset-based fees to receive the same service.
For these reasons, 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.