May 14, 2004
To Whom It May Concern:
I would like to first commend the SEC in its methodical effort to remind the mutual fund industry of its fiduciary responsibilities through punishing organizations and individuals who breach that standard. This will empower those voices inside and outside the industry that attempted to enforce higher standards.
However, I would like to understand the SECs overall intent to address these failings by key individuals through the use of an extraordinary amount of additional disclosure. Who is the targeted beneficiary of these changes?
My core concern revolves around the inescapable fact that the Prospectus is ignored by the vast majority of mutual fund investing public. Additional disclosure will fail to address this fundamental issue. Edward R. Murrow, a famous WWII reporter, was once heard to have said there is no news to report, if no one is listening.
I am of the opinion that the SEC has failed to realize that the investing public is not listening and more disclosure, albeit beneficial information, will just further disenfranchise the average investor from the wealth of information already publicly available. The SEC must recognize disclosure has to be repackaging to engage the investor or in four or five years we will repeat this process all over again.
The Plain English push of the late 1990s was in the right direction, but the proposed enhanced disclosure will undue all the good that came out of that initiative. We must change how the investor sees himself in this industry.
Thank you for your time and consideration.