February 29, 2004
Thank you for your letter of 12 FEB 04. I carefully read the enclosed draft forms and found them a nice first step towards full disclosure of all fees.
I would sugegst that ALL terms be explained--currently, a
number of them are not defined.
I would suggest that all fees be explicit over the course of the investment. I see the opportunity for deferred or reoccuring fees to slip through the cracks if the draft forms are adopted.
The letter mentioned that the SEC is considering similar efforts for other investments. I urge you to do that in a timely fashion.
One area that is in much need for clarity on fees is the variable annuity industry. In this industry fees on top of fees are imposed with fees varying as the investment value changes and over time. It would be nearly impossible for an individual investor to understand, much less calculate the fees owed. And of course, nowhere is designation of the fees discussed.
Norman Umberger, P.E.
The Common Sense Investor, Inc.