From: Kenneth L. Kust
I am a licensed insurance agent with New York Life Insurance Company and a registered representative with NYLIFE Securities. I am sending this email because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers.
It's frustrating to hear our government regulators speaking out of both sides of their mouths. One day they'll tell you how Americans aren't saving enough, and the next day there are new rules and regulations that further confuse and frighten the consumer and keep them from saving for their retirement with investments that have the chance to provide some type of growth.
That's what excess paper and forms do to consumers, especially our seniors. We want to be sure they're not being taken advantage of but making investing more complicated and paper intensive will keep many seniors and other consumers from doing what is in their own best interest.
The new rule you are proposing is sheer duplication. Mutual fund and variable annuity prospectuses already discuss the fees, risks and expenses associated with the purchase of these products. Why do we need another sheet of paper to spell out what's already in the prospectus?
Shouldn't we be calling attention to a mutual fund's overall return? Isn't that why consumers invest??? The prospectus already discusses fees and expenses! It's called "full disclosure!"
Some consumers resent the fact that I make a commission on the sale of any type of financial product. Calling attention to the fact that this is how I make my living might result in the consumer doing nothing because he or she doesn't want someone to profit from investing their money.
By creating more paper and calling attention to fees and expenses you will be stopping consumers from doing what they should be doing: investing for their future and the country's fiscal security. More people living off their own money means less people living off the public dole.
Why not focus your efforts on getting consumers to carefully read the prospectus they receive? A public awareness campaign would go much further than creating more paper and thus, more confusion.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
Kenneth L. Kust, LUTCF