From: Douglas J. LaBar
I am strongly opposed to your proposal on Point of Sale and Confirmation Disclosures as I feel it WILL HURT SMALL INVESTORS. My logic is as follows. I have been a financial consultant for 22 years. The bulk of my investors have over $250,000.00 in investable assets and we purchase individual stocks and bonds as this is most cost effective and the size of their accounts allows for proper diversification. I do receive a lot of referrals of smaller investors who may only have less than $100,000.00 to get started with. For these investors I use mutual funds to insure that they get proper diversification. I use "A" shares and fully disclose the charges and risks. So, my concern is not disclosure it is the fact that compliance with the new rules will be complicated, time consuming and very paper intensive. THIS WILL CAUSE ME TO STOP TRYING TO HELP THE SMALL INVESTOR!
A suggestion to help the small investor would be to make the prospectus simpler and easier to read. At the time of sale of each mutual fund I already provide each investor with a copy of the current prospectus and get a receipt showing I have done so. Disclosure of fees and other relevant information has always been in the prospectus and should remain there. An easy change to benefit the small investor (and all investors) would be to put all the sales charges and other relevant information on the front page in simple easy to understand language. To conclude I would ask you to please not hurt the small investor by making it more complicated to offer a mutual fund. Instead please help everybody by requiring that the prospectus show the relevant information upfront in simple easy to understand terms.