July 20, 2007
I am writing to express my concerns about the SEC's ongoing review of Rule 12b-1. Middle class Americans need the continuing service, guidance and support that are provided by independent financial advisors to achieve their stated investment goals. 12b-1 fees provide a tax efficient means to support the continuing service which these clients require for successful investing.
With the massive amount of redundant disclaimers, I ask you to think about the fees another way.
How will the small client get service? It costs more each year to service the smaller client as the amount of redundant paperwork disclaimers increase. Who will provide them service and how will they get service? If anything, the fee should go as the cost of soing business is substantially higher today.
The average returns for investors is substantially less than the index averages NOT because of churning or fund performance but because of bad investor behavior. Several studies have shown that investors make money money with an advisor. The reason?... they stay invested longer.
The process of a re-registration for whatever reason (marrriage, death, etc.) can be overwhelming to an investor. This is a service brokers provide including advice on the various options.
These fees allow for the establishment of long term advisor relationships with clients versus transactional relationships. This benefits the cleint in many ways not the least of which developing an understanding of the client Risk Tolerance profile. The little tests are great, but many clients are more conservative than the tests indicate and only a direct personal realationship will allow a broker todiscern this.
these fees allow the financial Advisor and client to discuss and review transactions of a financial nature that may not be directly involved in the "mutual fund sale". Would you prefer us to bill them for every phone call? They probably would not call.
Lastly, there seems to be an overriding drive to have brokers work for free. Is there a feeling that we provide no value? You do not work for free so why should we? Go and spend some time in the field to get a good perspective. I suspect that like cops if all you see is the "bad" situations day in day out anyone would get jaded. Please walk in our shoes not just read letters, comments, etc.
Sincerely,
MR LARRY MCCARTY
FINANCIAL ADVISOR
DIVERSIFIED INVESTMENT SERVICES