From: Christopher Fusco
Jonathan G. Katz
Re: SEC Proposal: Point of Sale and Confirmation Disclosures
Dear Mr. Katz:
Working as an independent financial advisor; it comes as a great surprise to me that the SEC is considering the confusing Point of Sale and Confirmation Disclosures in their current form.
As I read the briefing, it's clear to me that the subjectivity of one factor; that being cost, is the only reasonable basis in choosing between investments. The bias of this disclosure would so prejudice an investor in a manner that would make sound financial planning advice seem deviant.
Currently, if an advisor chose an investment for a client based solely on cost, he would be negligent of proper conduct and in my estimation would be in violation of the NYSE "know your client rule".
Frankly, many more factors go into making sound investment and planning decisions, liquidity, tax consequences and time horizons to name a few. Cost is an important factor, but to prejudice a disclosure form in a way that funnels an investor's thought process seems disingenuous at best.
The convolution of another legal form would only confuse investors further. A simplified prospectus with fee information seems a more logical approach to helping investors determine what investments are best suited for them.
Christopher J. Fusco, RFP, CTEP