From: Kenneth P. Werner
Hello, I am a financial planner with Lincoln Financial in Cleveland. In addition to financial plans, we offer insurance and investment services to help our clients reach their goals.
I am writing about the proposed new SEC requirement to add another, separate disclosure piece outlining fees for all mutual fund sales.
This is a duplication of effort. All this information is already provided in the prospectus which is given to every client and includes all relevant information for a client to invest (including fees). If there’s something else you want to include in the prospectus or if you want a different format I would suggest to make the adds/changes in the prospectus. The emphasis should be on consumers reading the prospectus because it not only contains information on fees, but all the other relevant factors in making an investment decision, such as investment objectives, philosophy, risks, performance history, management team, etc. Having a separate disclosure for any one aspect just doesn’t make sense. And the separate disclosure pieces just create more confusion for everybody.
I would suggest that you drop the proposed rule and. if necessary, include the desired information where it belongs, in the prospectus.
Thank you very much.
Kenneth P. Werner, MBA