March 15, 2004
The proposed disclosure of fee information
is very appreciated. The forms however
provide too many numbers, it is also
difficult to understand terms such as
front-end sales and back-end sales.
Section A: Good format as is.
Section B: Replacing costs with percentages would
be better.
Potentially split into three items:
a Fees paid at time of asset purchase:
b Fees paid at time of asset sale:
-if sold within 1 year
-maximum fee if sold after 3 years or more
c Annual fees to own asset
-first year fee
-following years
Disclosing industry norm is good.
Section C D:
Two sections could be combined.
Section C information could be combined
into one number. A list of costs increases
the risk that any new fee will not be
mandated and will go undisclosed.
Section E:
Discounts will already be factored into numbers
in section B. Consider removing.
Consider potentially adding requirement for providing
a URL to a page showing additional fee information
associated with the purchased asset. Similar
to how FCC requires telephone companies to
display their rates.