From: Jim Mabbutt
Jonathan G. Katz
Re: SEC Proposal on Point of Sale and Confirmation Disclosures
Dear Mr. Katz:
As a financial professional, I am concerned about the potential negative impact that the SECís proposal on point of sale and confirmation disclosures will have for investors.
As proposed, the SEC point of sale disclosure system would have the following unintended consequences:
It would substantially limit the number of mutual funds and variable annuities that I am now able to offer my clients.
This proposal misleads investors into believing that the lowest cost product is the most suitable versus encouraging investors to weigh all factors of suitability.
Ultimately the individual investor, my clients and me, will pay the added cost of implementing this proposal. Businesses are not charitable entities, so this change will force me the advisor to either increased my fees or limit the number of investment products offered.
As an independent financial advisor, I am currently able to offer my clients the most appropriate investment vehicles based on an unbiased assessment of their needs.
Rather than adopt the current proposal, I would urge the SEC to re-focus its efforts on incorporating important fee information into the prospectus and in turn, creating a more user-friendly prospectus that would better aid investors in their decision making process.