From: Jean Digrande
I am a licensed insurance professional and variable products salesperson and I am writing because I am very concerned that the new disclosure requirements, contained in the SEC's proposal to regulate the sale of mutual funds and variable products, is unnecessary. I start to see a "glazed over" look in my clients eyes as I hand them pages of disclosures and rules in addition to a thick prospectus. Since Mutual Fund and Variable Annuity prospectuses are reviewed by the SEC and already discuss the fees, risks and expenses associated with the purchase of these products, I believe duplicating the disclosure of these fees will lead to further confusion and put the emphasis on expenses, rather than on the importance of saving and investing.
I agree that it is important to make sure the customer understands the expenses involved with investing in securities. I urge the NASD to focus your efforts in requirements that make prospectuses clearer and easier to read. Since the Company I represent has done this, State Farm Mutual Funds, I find it quite easy to turn to the page that lists expenses and show my clients how the fees work, rather than just giving them a lot of documentation which they probably will never read.
I urge the NASD to withdraw the proposed rule.