From: Robert Dibley
Sent: March 29, 2005
Subject: File No. S7-06-04

Another knee-jerk reaction to a few bad apples in the industry!

The new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers. I am a licensed insurance professional and variable products salesperson.

A disclosure that discusses an investment's fees and expenses will lead people to focus on the investment's costs rather than its overall returns. After all, which is the better investment -- one with low costs and a net annual return of 2 percent, or an investment with twice the expenses and a net annual return of 6 percent?

Mutual fund and variable annuity prospectuses, already reviewed by the SEC, discuss the fees, risks and expenses associated with the purchase of these products. In 2002, the SEC took steps to simplify the contents of the prospectus. If you feel there are additional issues regarding the contents of the prospectus, focus your efforts on further revisions to the prospectus requirements; if you still believe consumers should be given a "one-pager," the appropriate document would be the table of fees and expenses found in every prospectus. Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus, create confusion as yet another document is thrown into the mix, and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus. Instead, the SEC should focus its efforts on getting consumers to carefully read the prospectus they receive.

I urge the NASD withdraw the proposed rule.

Thank you for your consideration of my views on this matter.

Robert Dibley