From: Michael Frailey
Jonathan G. Katz
I am a licensed insurance professional and variable products salesperson.
I hold Series 6 & 63 licenses.
I am writing to express my thoughts concerning the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products. In my opinion they are unnecessary and will provide no meaningful additional protection to consumers.
Mutual fund and variable annuity prospectuses already discuss the fees, risks and expenses associated with the purchase of these products. Any additional issues should involve further revisions to the prospectus requirements. Perhaps educating consumers to the importance of reading the prospectus they already receive would be a better use of SEC time and resources?
While I applaud the intent of SEC regulations to inform the consumer, I think continuous attempts to create more paper and more information for consumers to read is actually compunding an existing problem - too much information is not even reviewed. At the end of the day the consumer controls when they will or will not take the time to educate themselves.
They are presently being given more information than they can process - including disclosures on fees and expenses. There is no need for duplicative forms.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
Michael J. Frailey