October 27, 2010
Regarding File Number S7-15-10
As a licensed registered representative since 1991, I am supportive of SEC rules for the new 12b-2 fees. On going .25% fees for investment advice is prudent and not excessive for the investor. Also it allows the registered rep to be compensated for the input they give their clients.
I do have reservations however in the SEC allowing for a "net asset value" share class. This approach may sound good for competition and reduction of fees. But I will not be able to afford spending time with the smaller account holder. The smaller account holder will have to fend for themselves when they may have the least amount of time or experience to make investment decisions.
Thank you for your desire to reduce abuses and high expenses on all investors. Please keep in mind the advisory value in the education of investing process.
William F. Daines, II CLU, ChFC, LUTCF