November 25, 2005
Re: Unintended consequences - stifling innovation hurts consumers
Dear Mr. Katz:
By positioning unsolicited bundled products/services outside of the safe harbor, the SEC effectively outlaws what in any other industry would be considered good business practice. In a free market, good businesses seek to find new ways to improve client service in order to promote client goodwill and satisfaction. Often they do it at no charge, so that the client may try out the new product/service and become familiar with it.
If the SEC outlaws, or makes onerous the use of, this extra unsolicited service, they are in effect penalizing innovation and progress - and ultimately are hurting the advisors AND their clients. The effects of this regulation will stifle innovation in the investment industry and will consequently hurt the consumer, through fewer improvements and un-invented products/service or through higher fees.
Alexandra E. Stocker
Chief Executive Officer
Sanderson & Stocker, Inc.