From: Randy Blackwood
Jonathan G. Katz
Dear Mr. Katz,
Regarding proposal requiring disclosure of fees and charges on a separate form, I am totally against it. It would, by itself, give the consumer an unfair comparison of load vs. no-load funds. It would also unfairly compare proposals of different classes of shares, ABC etc. A clientl/prospect not clearly understanding the difference may draw an incorrect conclusion on which fund might best be suitable in the long run based on the fee's in the short run. It would also add just one more form in the process (duplicating the prospectus). I see know reason for the additional requirement. I also question what the form will look like when an investor is picking 5-10 different funds with different fees. Will each fund need a seperate form?
If you want to add a form, perhaps a simple signed statement from the client acknowledging that the Reg. Rep. has explained the fees and costs associated with the funds being purchased. This would simplify the process and should accomplish the same thing. I do training for the NYL and I always stress the need to review the fees and charges in the prospectus with the client. The form would emphasize the necessity to explain what is in the prospectus.
Thank you for listening,
Randy Blackwood, CLU, ChFC, MSFS, CLF