October 28, 2010
My name is Scott Leverenz. I am an independent financial planner. I have been a planner for approximently 20 years. I work with median income families and businesses.
I have looked at the proposed 12b-1 proposed changes and am very concerned these will do damage not only to the small to medium sized investor but to the advisor relationship with them.
I could agree that more disclosureof fees and sales charges would not hurt. I think it is overkill though, as people want a good relationship with their advisor and one that will help them. They know we are compensated and most people do not want to make the relationship one of fees vs quality of service. If fees becomes the big issue vs quality and time one can give the client ,then the client suffers. We cannot really accept less pay for what we do either. This is a tough business with the independent financial advisor working up to 60-70 hours a week including weekends.
Capping 12b-1 and C shares will also make it hard to impossible to help many small client who cannot fit into a fee based model. Our clients expect us to service their needs every year. We need to get paid for our services. So the only alternative may be to not service the small to mid size investor. If we were able to convert them to a fee based account, we may have to even charge more for our servcies for the extra work we have to do.
I have been helping people with their financial plans for 20 years and I have don`t have issues with providing quality and time with my clients with the current structure. My clients understand I need to be paid and value my time with them and the quality of my service more than what type of fee I may be paid. They know i must be paid on an on-going basis.
Also, I do not agree with the proposed rule to allow mutual funds to offer a share class at NAV, and allow advisors to set their own fee and bill clients directly. This will only give large mutual fund companies an advantage over the small to mid size financial advisor firm. We cannot compete with the large institutional firms on fees, but we can on quality of service and individual advise. Quality may cost a littl more up front and most people are willing to pay a little bit more for personal local service vs purchasing products from a large company with little help.
Thank you for your time to read this. While I can agree with more disclosure of what the fees are for, I urge the SEC to reconsider its efforts to cap sales charges and encourage retail price competition. I feel this is only going to drive the quality of service downward for the public.
Sincerely,
Mr. Scott Leverenz
CRPC
Financial Resource Group