From: Frank Prescott
Jonathan G. Katz
I have just sent a response regarding your proposed rule change to require yet additional disclosure of fees and costs associated with the purchase of mutual funds and variable products. The response was generic and simply a boiler-plate form letter written by NAIFA. I agree fully with their position, but feel compelled to add my own comments.
Where does it stop? Is there a group of professionals under closer scrutiny than sales reps and broker/dealers involved in the sale of securities? How much more redundancy is needed before the general public just throws up its hands and says "No Mas", "This must be a bad thing, I'd better not invest. I'm just going to bury my money in the back yard in a coffee can so no one can steal it."
When I sell a mutual fund, I already review the prospectus with my client.
As we fill out the New Account Form, Disclosure Form, Mutual Fund Worksheet, Switch form (if recommendation includes moving money from one fund family to another), Share Class disclosure and myriad other potential forms required of my broker/dealer my client's eyes are already glazing over and we haven't even filled out the actual mutual fund application.
My broker/dealer does an excellent job of monitoring the sales process from initial contact with the client right through to being sure that all the Is are dotted and Ts are crossed on all requirements for the protection of the client and sales rep. If you feel that additional measures are necessary, it should be accomplished through restructured prospectuses. All of the information necessary for a customer to make an informed decision on whether or not the purchase is appropriate for them is already included in the prospectus.
I urge you to reconsider the imposition of yet another form that is really unnecessary.