November 1, 2010
I am a licensed insurance professional and registered representative of almost 5 years. I do support the new SEC rule 12b-2, which continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SEC's 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.
I do not agree with 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. Competition based on price will come at the expense of needed advice and service for middle market investors.
I mostly serve the middle market client and if my compensation was cut I would not be able to afford to help those individuals as I do today. The way it is now barely makes it feasable to provide the service they deserve. Please consider who you will really be hurting if you allow mutual funds to create this new share class.
Thank you,
Kyle Herman