From: W. Robert McVitty Jr.
Jonathan G. Katz
I am a licensed insurance professional and variable products salesperson.
I am writing to you because 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.
We provide prospectuses to new customers as required by the SEC. I agree that the typical Prospectus is somewhat intimidating and is probably not fully understood by the intended reader. I also believe that the prospectus is the proper disclosure document.. If reform is necessary, I believe that efforts to simplify the prospectus is where time should be focused. Reduce paper, use bold type, eliminate jargon. Do not add additional disclosure documents . Mutual Fund buyers should not have to have formal legal training or a strong accounting backgroud to understand a prospectus.
I think the proposed NASD rule will add another compliance layer to the typical transaction and duplicate information that is already provided within the prospectus. For that reason, I believe the NASD should withdraw the proposed rule.
W. Robert McVitty Jr,. LUTCF