From: Michael Ruff
Michael Ruff, CPA/PFS, CFP, CFE
March 31, 2005
Jonathan G. Katz
I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products have the potential to harm consumers. I say that from my 30 years experience in dealing with client financial matters.
Disclosures that only discuss investment fees and expenses will lead people to focus on the investment's costs rather than its overall returns. In the real world, an investment with low costs and a net annual return of 2 percent, or an investment with twice the expenses and a net annual return of 6 percent exists. Same thing applies to oil well investments - the lower cost could just as easily be a dry hole while a higher cost drilling prospect could be completed as a good producer. I've seen that very thing happen.
For these reasons, I urge the NASD withdraw the proposed rule.
I appreciate your consideration of my views.
Mike Ruff, CPA/PFS, CFP, CFE