April 1, 2005
I appreciate the efforts being made to improve disclosure to securities clients at the point of sale. However the current proposal is being rushed through, not affording adequate time for interested parties to respond, address concerns and offer valuable input.
My specific concern is the quality of disclosure and that it is provided in a way that is easily understandable to the client. Given the current state of prospectuses and other disclosure requirements, simplicity is not a given. The more confusing things are to the client the more they depend on the advisor/rep/broker to explain it all to them. This may defeat the purpose of the written disclosure.
I urge you to give this more time and extend the response time for another 60-90 days.