Subject: SEC's Proposed Amendments to Form ADV Part 2

May 12, 2008

I don’t think it makes sense to add another layer of regulations. Why not prosecute the bad guys to the fullest extent of the law, and leave the good guys alone?

In 13 years as a stockbroker, 11 years as an IAR, I have had only one client that actually read a brochure, and it was actually a brochure on long-term care insurance. Every client that comes in the door, we hand them prospectuses for mutual funds if we are recommending them, and they say, “You know I’m just going to throw these in the trash, why give them to me, save a tree.” And I tell them, “We are legally obligated to give them to you.” Then, a few days later, the brokerage firm we use to custody client accounts sends them another prospectus. Then the fund company sends them an annual or semi-annual update.

EVERY one of these documents get thrown in the trash.

We were told about 7 years ago we were going paperless. It seems that we purchase and use more paper than ever.

Clients rely on trust, not disclosures or legal ease.

Again, “Why not prosecute the bad guys to the fullest extent of the law, and leave the good guys alone?”

Thanks for reviewing my input.

Laurence E Menna
Financial Planner, RJFS
President, MCM