November 4, 2010
File Number S7-15-10
I am aware of the changes to the current 12b-1 fees and wanted to submit my comments. I have been a licensed insurance professional and registered representative for more than 20 years. I support the new SEC rule 12b-2, which would continue the current 25 bps fee to ensure ongoing service and advice, and the SEC's use of the terms "marketing and service fees" in order to improve the transparency. However, I strongly object to allowing the mutual fund companies to issue new NAV priced shares so that the broker/dealers can make their own pricing. While this may seem like a good idea, I am concerned that the b/d community will lower the front end sales charge to such a low level that it will not be profitable for me to serve the middle income market any longer. My clients would need to meet account size minimums in order for this to be profitable for me and the middle and lower income clients I now serve would need to self-direct their accounts. The people the SEC is trying to protect would actually suffer from this new arrangement.
Thank you for your consideration,
Mark D. Olson, CFP, MSFS, CLU, ChFC, LUTCF