From: Richard W. L. Hall
Re Point of Sale and Disclosure Proposals.
I am Certified Financial Planner, registered rep, my onw NM State RIA.
I have been on the board of directors of the NM IAFP, and FPA.
I have been a teacher of Consumer Protection and Financial literacy.
Many of my clients have fee nly relationships with me but I also sell variable procducts by commission.
I am very committed to full disclosue to my clients and aside form my ADVII provide a booklet outlining all my business relationships and possible conflcits of interest.
If anything I am extreme in my views towards consumer protection, ethics and disclosure.
Most of the requirements to in form the public investor have doen exaclty the opposite. When I sell a varialbe product the prospectus are so large that I have to send them in 2 envelopes as they exceed the 16 oz mail limit for stamped envelopes.
I have a very highly educated cleintle and NO ONE reads the prospectus. They take one look at the hundresn of pages of fine print and throw them away.
The whoel process in enviromnetally unsound and works againsthe interst of the consumer.
Expenses should be fully disclosed but if you canít cover everything on one page of large print in plain language then you are hampering the very process you claim to promote.
I have only read summaries of the proposals however.
Confirmations of transactions must come from the receiving company that invests the funds. Many of my clients send money in directly and I have no knowledge of this until well after the fact. I do not hold custody of any funds and if I have to be involved in confirmations for hunderds or thousands or small and sometimes a regular automatic payments I would have to totally change my business modle and perhaps cease operations.
I can sell over 4600 mutual funds. The point of sale disclosures would seem best if they were part of a simple one page general descriptions that points to a web site where the individual funds could be reviewed.
Donít kill the independants who provide the broad options and objective advice to their clients and bolster the large unethical wire hosues pushing their own products.
The independants are the kights in shining armour donít drown us in paperwork.
I am a fiduciary to my clients. My ethical standards and expectatiosn are the highest, but simply passing more regulatiosna nd creating mountians of paperwork can destroy those of us that are tryignto do good and workls asgainst the interests of the investor.
Consider a free look period such as with varialbe products where the investor can get his money back at the market value (not necessarily the original investment) but free of any sales costs or penalties.
Try to be part of the solution not compoundinghte problem.
:-) Richard W L Hall RIA,CFP(r),ChFC,CDFA
Web Site: www.bhwealthmanagement.com
Hourly Fee Financial Planning offered through Richard W.L.Hall RIA.