From: Larry Larmee [llarmee@ifpaam.com]
Sent: Thursday, January 22, 2004 6:19 PM
To: rule-comments@sec.gov
Subject: New Confirmation and Point of Sale Disclosure Requirements

Based on my experiences with clients, as a CPA for 30
years, most investors don't have a clue as to what
they are paying when they buy load funds from a broker
or commission based financial planner nor the past
performance of these funds nor the conflict of
interest. I applaud your proposed requirements.Here
are my disclosure recommendations:

1. Require that every broker/planner be required to
disclose in writing the annual operating expenses both
as a percentage and in dollar terms of every fund
he/she sells with a side by side comparison of the
average operating expense for comparable funds as a
percentage and in dollar terms.  This will highlight
the high expenses of Class B funds and other funds
with high operating expenses. The costs of an
investment are the only thing the investor can
control. They need this most basic information to make
an informed decision.  

2. Require that front-end and back-end loads be
disclosed in writing both in percentage and dollar
terms and how they work in plain English. In addition,
require a schedule showing the time frame during which
the back-end load goes away.

3. Require that the broker/commission based planner
provide each customer with performance information
showing the percentile historical performance ranking
for each fund over 1, 3, 5 and 10 year periods as
calculated by Morningstar for comparable funds. 

4. Ensure that the conflict of interest disclosure be
in plain English, perhaps with an example, using
dollars and cents.  

5. As evidence that the prior disclosures have been
made, require the customer to sign an acknowledgement
at the bottom of the disclosure and the
broker/commission based planner retain that
acknowledgement as evidence of compliance.  

If you have any questions, my office telephone number
is 248-646-6044.