November 3, 2010
To Whom it May Concern:
I have been in the insurance business as a registered rep for over 20 years for Farm Bureau Financial Services in western Nebraska.
I would like to voice my support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice (which is crucial to small investors in particular), 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 and understandability in disclosure documents.
I do not support the SEC permitting mutual funds to issue a new class of shares at NAV that would allow BD's to set their own sales charge and commission amount. I have run into many clients who have bought what they thought were "No Load" shares over the internet with no explanation of the difference in share classes in the current system. This new class will make it even more confusing for the public along with making it less likely that thy will have any guidance in judging the risk they assume and expenses they incur along the way. It will hurt the small investors who cannot afford to pay "Assets Under Management" fees. As a professional I need to be compensated for the service I give to my clients and I feel that this proposed change will really make it less likely that I will be compensated enough to pay for the time I need to invest in my smaller clients. Is this really a service to them? I do not think it is. Protect the small fish. Thanks for your attention to my thoughts.
Mark Mendenhall, CLU, ChFC