November 1, 2010
File Number S7-15-10
I have been a licensed insurance and investment professional for 12 years. I support full disclosure and transparency in all products and services. I support the 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 SECs 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.
I believe in the free marketplace. The SEC has no business in setting restrictions on pricing, fees or expenses in the marketplace. Just make sure that all fees, expenses, and commissions are fully disclosed and transparent. Let the free market work. Let the consumer compare pricing and service models in the marketplace and let the consumer decide whether or not there is value in higher or lower fees and expenses. The rules of the game should be fair, reasonable and disclosed for everyone to follow.
Thank you for you time and consideration. Steve Summa