From: Gary L. Noecker
Jonathan G. Katz
Dear Mr. Katz:
I know that all government officials want to "do good" and prove that they are helping their constituents by developing new rules and regulations, policies, etc. When will the SEC realize that enough is enough? The new point of sale and confirmation disclosures that have been proposed would dramatically reduce the number of mutual funds and annuities that I can currently offer my clients. Implementing this proposal will dramatically increase costs for the investment companies as well as the broker dealers, and ultimately the customer who you are supposedly trying to protect will pay the added cost and will probably end up being more confused than before.
There have been problems with the mutual fund industry as well as the insurance industry although not nearly as bad as Mr. Spitzer would have the American public believe. Our industry is doing a great job of addressing those problems while trying to maintain and not undermine the American public trust.
The system works in its present form, the solution is to get the lawyers out of the prospectus writing business and have the SEC refocus on creating a more user-friendly, easy to read and understand prospectus that clients would be willing to read.
Because governmental regulators and lawyers have been on a never-ending roll the past few years, the Paperwork Reduction Act of 1995 and the Small Business Regulatory Enforcement Fairness Act of 1996 are continuously being violated.
I strongly urge the SEC to re-think about what is truly in the best interest of the American Public.
Gary L. Noecker