Subject: File No. S7-06-04
From: Michael T. Wahl
April 8, 2005
unfortunately, momentum in disclosure is taking momentum and life of its own. with each passing day, compliance and disclosure eats up more and more of the time that is otherwise spent on servicing the public. i do appreciate the intent of compliance and disclosure. the unfortunate result is that it becomes less and less possible to do good for but a more limited number of prospective clients, especially the smaller prospective clients.
i think that it is safe to say that i now spend 20% of my time on compliance and disclosure paperwork. i have an excellent record of service to my clients without the imposition of layers upon layers of additional paperwork. what with forms changing at an ever increasing pace to keep up with additional nuances in disclosure and compliance, larger and larger amounts of forms are discarded as if there were an infinite amount of trees to be cut down.
a staff member in our office complained about how difficult it is to keep forms supplies stocked to keep up with the dynamics of compliance and disclosure. quite often, i have to go back to what i thought had been properly processed new business and start all over with the paperwork because of some otherwise immediately changed form. my clients cannot be much better served than they already are no matter how much more additional requirements are promulgated. the result will physically have to be to reduce the number and size of the clientele i serve. for myself, continuing escalation of paperwork is simply doing more disservice to the population at large than the good that is otherwise intended.
and if the intent is to reduce costs for the buying public, the opposite is the real result. there is so much misspent time and effort ....... and money being spent to satisfy spiralling regulations that the public cannot help but get hurt in the process. if the intent of regulators and state attorney generals is to create endless paperwork, they are doing a great job. but, i cannot help but think than on the balance, more harm is being done to the public than good despite the good intentions.
michael t. wahl