March 8, 2004
March 8, 2004
As a registered representative, I am dismayed at all the disclosures that are being proposed in the SEC Rules 15c2-2and15c2-3. Investors are already inundated with information and forms and find it difficult to comprehend. Any more disclosure detail will further confuse them and it will turn them off.
The mutual fund industry is beginning to resemble the IRS tax code incomprehensible, overbearing and unfriendly.
Before you start ripping the mutual fund business apart, please take the adequate time to thoroughly understand the 100 plus pages of changes and their impact on the personal investor and the Registered Reps. The 60 day comment period is hardly enough time consider the far reaching consequences of these actions. Please extend the allotted time to 120 days.
Over the last few months, I have been taking note on how the mutual funds are implementing new exit fees. These are usually 2 on money exchanged in a fund group within 5 days to 2 years. The Idex Transamerica Mutual Fund Company has restricted access to a clients IRA withdrawal plan once it is established. They can only request a withdrawal amount once a year and it cannot be change for that time period. What a delightful rule. It certainly is not helping the small investor and is costing them money. Why is the small investor being punished for the sins of the hedge fund companies, investment managers etc.? All this in the name of compliance?
The elimination of 12b-1 fees will result in chaos and severe dislocation in the mutual fund industry. The 12b-1 fee that is paid to me, enables me to provide the necessary service to my clients at no additional charge or fees, which I have done for the last 19 plus years. If the fees are eliminated, I will be forced to charge an hourly fee or a 1 asset charge. This certainly will be far more costly to clients than the current 25 basis points.
Implementing these far reaching decisions will also be burdensome and costly to the Registered Reps. I believe it will discourage new people from entering the industry and perhaps encourage older representatives to retire. This would be disastrous as most small investors are not sophisticated enough to survive market and economic changes without our assistance.
Please understand that the changes you are considering will have major consequences to both the investor and the Registered Reps.
Thank you for your time and consideration.
Donna M. Wolf, CFP