March 26, 2004
I very much appreciate the SECs proposed forms, as Ive found it impossible to figure out American Express Financial Advisors fees. They do a good job of keeping fees hidden in the multiple page portfolio statements. Your forms are clear as to fund price and brokerage fees.
I see no difference between Atachments 2 and 3, other than the titles, i.e., ...present or future. Please explain.
Will the SEC establish and maintain the Industry norms: Range and Median in Attachment 2, section B? I can see different brokerages using different numbers, if they are expected to furnish the norms.
Two points in time as proposed is perfect, i.e., Point of sale and afterwards a confirmation statement.
Tracking subfunds can be a problem for investors, e.g., American Express has several VP funds that are not accessible through normal access media like Barrons and Morningstar. These should be identified before buying.