November 3, 2010
I am a licensed insurance professional and registered representative for over 30 years.
The new SEC rule 12b-2 that would ensure investors receive ongoing advice and service by continuing the 25 basis points fee and the proposal to simplify the language with terms "ongoing sales charge" and "marketing and service fees",replacing "12b-1 fees",are excellent new proposed rules.
However,the SEC proposal to "encorage retail price competition" by allowing mutual funds to establish net asset value share classes which would allow broker-dealers to set their own sales charge and commissions is not such a great proposal. This would hurt the middle and lower market investor who the rule is trying to protect the most. With price competition driving down the fees, it will no longer be financially feasible for a registered rep. to advise the smaller investor...only the upper-income investor will be able to afford the higher cost/higher service classes of shares or assets-under-management arrangements. Unfotunately, this part of the proposal I do not support.