From: Charles Roe
Jonathan G. Katz
I am a licensed insurance professional and variable products salesperson.
I am a Chartered Financial Consultant and am studying for more designations. I am concerned about the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products. I believe they are unnecessary and will provide no meaningful additional protection to consumers.
I am very, evry interested in any measures that will simplify the process of purchasing these products for my clients as well as myself. I believe the amount of paperwork already required overwhelms the consumer and hampers my ability to do do my job efficeintly. I believe adding another form to the already large stack of paperwork is counterproductive. I would suggest making further revisions making prospectuses easier to read and understand as opposed to adding more. Clients are already shocked at the amount of time and effort they and their advisor spend on paperwork.
It is possible that it gets to the point that they simply don't want to deal with it. That in itself is not good at all. Because there is so much they sign without bothering to really understand what they are signing. If you still believe consumers should be given a "one-pager," the appropriate document would be the table of fees and expenses found in every prospectus. Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus, create confusion as yet another document is thrown into the mix, and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus.
Instead, the SEC should focus its efforts on getting consumers to carefully read the prospectus they receive.
Finally, a disclosure that only discusses an investment's fees and expenses will lead people to focus on the investment's costs rather than its overall returns. After all, which is the better investment -- one with low costs and a net annual return of 2 percent, or an investment with twice the expenses and a net annual return of 6 percent?
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
Charles E. "Gene" Roe CHFC