Dear Department of Labor,
I am writing with regard to your proposed fiduciary rule
As you know, you’ve stated several times in that proposed rule, that Americans have lost billions of dollars in their IRAs and company retirement plans because their advisors used broker sold funds (loaded mutual funds that pay the seller a commission) instead of no load funds, which have a lower annual expense (because they pay no compensation to the seller).
I have read your rule twice, examining your assertions that the difference in annual expense to the investor between broker sold funds
and no load funds has amounted to billions of dollars. Now, as I am sure you know, advisors who use no load funds either charge a fee to the investor for advice, or they work for free.
And not many advisors work for free.
I’ve looked and looked to see where you’ve taken those advisor-charged fees
into account in your calculation of the annual expenses of both alternatives, but I cannot find it. I’m certain you didn’t simply ignore those fees as that would be patently dishonest, so I’m just wondering: What level of fees, charged by advisors who use no load funds, did you assume in your calculations?
John L. Olsen, CLU, ChFC, AEP
St. Louis, MO