October 27, 2010
Elizabeth M. Murphy, Secretary
Securities and Exchange Commission
100 F Street, NW
Washington, DC 20549-1090
Re: File Number S7-15-10
Dear Ms. Murphy -
I have been a licensed insurance professional for 12 years and a registered representative for over 8 years.
I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SEC's proposed use of the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees" to improve transparency in disclosure documents.
However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount.
Currently I see middle and lower market clients of which other advisors have chosen not to represent as they have smaller fund account balances. This decision not to help middle and lower market clients is in part due to the amount of paperwork required by compliance that takes more time to complete and spending additional time to provide the level of individualized advice results is a financial loss to the representative.
I believe that as broker-dealers lower their sales charges and fees; this will result in even more registered representatives such as myself no longer representing middle and lower market clients. They will be hurt the most, since they will be deprived of the guidance and service they need and deserve.
Thank you for the opportunity to express my concern.