From: Michael L. Kleen
Jonathan G. Katz, Secretary
I am writing because of the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products. As a licensed insurance professional and variable products salesperson, I believe the new disclosure requirements provide no meaningful additional protection for consumers.
The required prospectuses, reviewed by the SEC, already discuss fees, risks and expenses associated with the purchase of mutual funds and variable annuity products. If there are additional issues regarding the contents of the prospectus, focus should be on further revisions to the prospectuses themselves. If there is a need for a 'one-pager', the table of fees and expenses found in every prospectus could be used. The new requirements duplicate information already found in the prospectus. The addition of other forms will merely create confusion and reduce the likelihood consumers will read the most important source of information on the product - the prospectus.
The new requirements only discuss an investment's fees and expenses leading people to focus on the investment's costs and not the overall returns. It is the net return that should be focused on. I urge the NASD to withdraw the proposed rule.
Thank you for considering my view on this matter.
Michael L. Kleen CLU, ChFC, CFP