Subject: File No. S7-06-04
From: John M. Shartrand, AAMS, ChFC
Affiliation: CAPCOM Financial Services
April 4, 2005
Dear Mr. Katz
I can appreciate you wanting to help the individual investor, In the end both you and I are individual Investors.
I work in a small Firm with 1,800 active clients who use mutual funds and depend on an Advisor to help them. We currently have access to over 17,411 mutual fund investments and variable annuity sub accounts, Do you really believe the biggest issue is how much they pay at point of sale?
When I see legislation focusing solely on disclosure of fees " To help the Individual Investor" I get a little frustrated. The success of an Individual Investor depends on professional guidance and education NOT Fee disclosure, yet that has been the focus. I have been in the business for over twenty years and I have seen more people fail in real life based on making wrong decision then I have seen people succeed because they saved twenty basis points on an investment they picked.
When I started in the business it cost 8.5% to buy a mutual fund up front. As more individuals held mutual funds and more companies got involved magically the cost reduced. The pressure from the competition has and will continue to control expenses Not a disclosure sheet, in fact you can make an argument that it will complicate the issue and distract the individual investor from the real issues, The need to plan and save.
It has taken years to get the individual to get used to the prospectus. Re-inventing how you disclose things will not help the Individual. Please feel free to call or write and I would be happy to help in any way. Thank you for your consideration in this matter and I hope my insight from the field helps. I understand you wanting to help the individual and I applaud you efforts. In the end it comes down to individuals helping individuals and trust in a professional, NOT whether a disclosure fact sheet is better than a prospectus.
John M. Shartrand, AAMS, ChFC
Chief Investment Officer
CAPCOM Financial Services
or visit us at www.capcomfinancial.com
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