October 27, 2010
First off, I would like to thank you for working so diligently for our clients and industry making some needed adjustments are made. I have been an independent licensed financial professional for 6 years, and I am in favor and support the new SEC 12b-2 rule, which would continue the 25 basis point fee that is used to ensure more mid level investor support for ongoing service and advice. I am also in favor of the transparency and rewording of the 12b-1 fee to "marketing and service fees" and "ongoing sales charge." 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. As broker-dealers lower their sales charges and fees in an effort to gain market share, it will no longer be financially feasible for registered representatives to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients. As a result, only upper-income investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advice. I see this being a big issue with big banks buying up the old traditional wirehouses and more and more mid level investors are falling below the mega bank minimum thresholds to get quality advice or service. Thus investors with smaller fund account balances will be forced to self-direct their accounts if they wish to continue to own mutual funds because their advisors will no longer be able to afford to spend the time to guide and advise them, leaving discount brokerage fund platforms as the only affordable option for middle and lower market investors. Thank you for your time and consideration.