October 27, 2010
I have been a licensed insurance professional and registered representative for many years. I support new SEC rule 12b-2 and the SEC's proposed use of the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees". However, I have concerns regarding allowing mutual fund companies to issue a new class of shares at net asset value. This will lower compensation and tend to have a negative impact on the ability of a transaction-oriented sales person to make a living. The process by which commissions are paid now is relatively simple and easy because it is done through the mutual fund company. The idea that you will encourage competition by requiring that process to include negotiation, billing and then collection makes no sense. The impact on the sales person aside, why would a broker/dealer want to do that??
Doug Richards
Insurance Designers