Subject: File No. S7-06-04
From: Eric B. Soik, LUTCF
Affiliation: New York Life Insurance Company
March 30, 2005
In this important era of compliance and suitability, security/variable
product transactions require a prospectus be given to the applicant. This
prospectus already contains full disclosure to include principal
investment strategies, principal risks, and fees and expenses of the fund.
Other factors of investment objective, time frame, risk tolerance are
critical. By duplicating disclosure efforts, it seems we would be
improperly helping prospects and clients focus their decisions on cost
alone? I fail to see how this micro perspective is well suited in this
important era of compliance and suitability.
Eric B. Soik, LUTCF
New York Life Insurance Company
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