From: Hershel S. Meriwether II
Jonathen G. Katz, Secretary
I am writing to comment on the SECs proposal to require new and additional disclosure requirements on the fees and expenses and other costs of purchasing mutual funds and variable products. I am a financial professional and registered representative with a Series 7 license and life insurance and variable product licenses. I've been in the financial services industry for over 15 years and prior to that a state government budget and policy analyst, and an individual investor in mutual funds. In my opinion, the proposal's new disclosure materials essentially duplicate requirements already in place, namely the contents and delivery of the mutual fund or variable product's prospectus.
A few years ago the SEC simplified the contents of the prospectus which now clearly explains the fees and expenses of these investment products. There is no need for a separate "one-page" or more disclosure document. This approach would run counter to the SEC's efforts to simplify the contents of the prospectus - which is what every investor should read. A separate page about costs won't help the investor understand the risks involved in investing or how to develop a suitable, diversified portfolio - which are the main problems. Low expenses are usually a good thing, but less important than the performance and suitability of the investment (from a risk and return standpoint) for the specific investor.
I go over the prospectus with each client and we discuss all the factors that would effect suitability and the client's decision to purchase the mutual fund or variable product. A separate disclosure duplicating the expense information in the prospectus is simply unnecessary and may actuallly be more confusing for the consumer. But if you believe consumers would be better off with more information on fees, I suggest re-doing and/or simplifying the table of fees and expenses found in every prospectus. For these reasons I respectfully encourage the withdrawal of the proposed rule.
Hershel S. Meriwether II, ChFC