From: Elwood Syverson
Sent: March 29, 2005
Subject: File No. S7-06-04

Elwood Syverson
115 East State Street
Mauston, WI 53948

Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Jonathan Katz:

I am a licensed insurance professional and I also market variable products such as variable annuities, variable life insurance and mutual funds. I am writing to you because I have recently become aware of the the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products. The paper work associated with the sales of variable products is already onerous and this recomendation is clearly redundant. All licensed securities agents are required to deliver a prospectus which includes all of the items that are on the new form.

This form will provide no meaningful additional protection to consumers.

It actually will encourage them not to peruse the prospectus and actually learn about the costs associated with variable products.

As you are aware, Mutual fund and variable annuity prospectuses, which are reviewed by the SEC, already discuss the fees, risks and expenses associated with the purchase of these products. Very recently, in 2002, the SEC took steps to simplify the contents of the prospectus. If you feel there are additional issues regarding the contents of the prospectus, focus your efforts on further revisions to the prospectus requirements; 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.


Elwood Syverson, LUTCF