From: Mike Thompson
For the sake of convenience, I am sending you my comments regarding this SEC proposal via e-mail as opposed to sending them in writing.
It is my understanding that this proposal would require registered representatives to provide their clients with additional disclosures regarding fees and expenses of variable annuities and mutual funds.
It is my feeling and my opinion that this practice would duplicate efforts that are already being made to adequately disclose this information to clients. Currently, sufficient information is provided through a prospectus. Moreover, most broker-dealers (mine included) have established internal controls to ensure that the client is well informed through different means and that the recommendation is a suitable one.
In my business, it is common for my clients to be more concerned with the volume of paperwork required to complete a transaction than any other concern that they voice to me. Implementing this practice would be redundant, duplicative, time-consuming, burdensome to the client, unnecessary and a waste of time and resources. I would hope that the SEC and that the NASD would put their efforts into bridging the apparent communication gap that, in my opinion, exists between the two entities - as opposed to seeing who can come up with the most stringent guidelines to guard against indiscretions by a select few representatives in our industry.
Thank you for your time and attention to my correspondence.