From: Paul B. Wolf
Re: Point of Sale and Confirmation Rules.
My comment is probably different from others in being more general. But I think the proposal that would significantly increase a registered representatives paperwork would be burdensome and counterproductive to require more disclosures beyond the prospectus. Since most B/ds deal with thousands of different products it isnt feasable
It seems that by constantly requiring more and more disclosure, the average client feels inundated with literature and as a result important information gets buried due to the sheer volume. Its like a word puzzle for children at a Diner where they need to find the hidden words among the many extra letters that serve as a distraction. I believe this has already happened.
The average representative deals with the same clients year in and year out and takes good care of them because we care about their financial well being.
Many representatives are feeling simply overwhelmed and we are being overregulated with each passing year since their are always new requirements, such as privacy policies, patriot acts, disclosure rules, Reg 60 and yet nothing is ever simplified and rarely is a rule scrapped. It seems that the paperwork overload is slowing this business to the point where it sometimes no longer feasible to service small investors or for us to stay in business.
It seems the only profitable part of this industry is quickly becoming the compliance providers. You cant enforce Honesty and Integrity by more disclosures, we all shouldnt pay for a few bad apples.
Please reconsider the rules and keep it simple for the public and industry. Thank You.