From: Kristin Hunnibell Kennedy
Jonathan G. Katz
Re: File Number S7-06-04
Dear Mr. Katz:
I am writing in comment on the Commission's proposed rule on point of sale and confirmation disclosures of mutual fund transactions.
While appreciative of the SEC's desire to ensure investors are fully informed when making mutual fund investment decisions, I am strongly objecting to the manner proposed to supposedly accomplish this.
I believe presenting a summary document ("Profile Plus") unless presented within the prospectus, would have an opposite effect than intended. Investors will read this summary, assume it's the information they need to know and will never even open the prospectus. The prospectus contains vital information necessary for clients to make informed investment decisions. That is the reason for a prospectus. Educating investors about the importance of all the information contained within the prospectus is where our focus should lie. Our industry's registered representatives work hard to accomplish this task. We should not chop the prospectus up into bite size pieces to make it appear more palatable to investors and as a consequence have additional important information overlooked by clients.
I have an even stronger objection to the aspect of the proposed rule that requires profiles, for every class of every mutual fund a firm offers, be posted on the firms website. The costs associated with implementing that aspect of the rule would be prohibitive for a small firm such as ours. Producing a legally compliant profile for every fund and class, posting them on our website, maintaining them and keeping them up to date would be extraordinarily expensive.
If this rule were to be implemented as proposed, we would find ourselves in the unhappy position of significantly restricting the number of funds we offer our clients in order to be able to adequately maintain these profiles. We do not see limiting investor choices as a positive step, but economically would have no other option.
Please give consideration to the financial impact your proposal will have on firms, all for the purpose of duplicating information already contained within the prospectus.
Kristin Hunnibell Kennedy
ARTHUR W. WOOD COMPANY, INC.
Investment Securities Since 1899