Subject: File No. S7-06-04
From: Jon M. Black, CLU
March 30, 2005
This is in reference to the proposal to add new disclosure requirements to the sale of mutual funds and variable products. I am a licensed insurance professional and variable products salesperson. In 2002 the SEC made revisions to the prospectus that lay out the fees in a much more understandable format already. Additionally, I am required by my Broker/Dealer to have a disclosure checklist signed and initialed by my customers that confirm we have discussed the fees and expenses of the investment they are making. The addition of a page that will only disclose fees and expenses is not only redundant, it will also serve as a source of confusion and diversion from the benefits of a well structured and managed investment plan. Finally, if you still want to effect additional changes, why not just require the prospectus to include what you are proposing as the first page?
For the above reasons, I urge the NASD to withdraw the proposed rule. Thanking you in advance for your consideration of my comments.
Jon M. Black, CLU