From: Kevin Polheber
Jonathan G. Katz
Re: SEC Proposal
Dear Mr. Katz:
Most financial professionals, such as me, have concerns about the potential negative impact that the SEC's proposal on point of sale and confirmation disclosures will have for investors.
Independent financial advisors should have the ability to offer my clients the most appropriate investment vehicles based on the clients investment objective and risk tolerance. The SEC point of sale disclosure system could limit the range of investments that we have to offer. This will potentially affect my hundreds of my clients in addition to countless thousands mutual fund shareholders.
Many advisors believe that the cost of the investment is not as important as the realized rate of return earned by the shareholder.
It has been communicated to me that the SEC proposal being considered may come at an enormous cost that will most likely be passed to the shareholder. It would be unfortunate if that comes to fruition.
Over the fifteen years of my career, the continual word on the street was that the SEC was going to be instrumental in making the mutual fund prospectus more user friendly to the common investor. I would suggest that the SEC work toward that end in lieu of such a drastic measure as proposed.