From: Randall Young |
Jonathan G. Katz Re: SEC Proposal on Point of Sale and Confirmation Disclosures Dear Mr. Katz: I am very concerned about the potential very negative impact of the SEC’s proposal on point of sale and confirmation disclosures will have on my clients and future clients. I am a registered representative, series 7, 65, 63 and 24. I garner most of my income from investments. I also have a book of business of well served clients that have been inundated with impossible amounts of disclosures and paper work. This has, in most cases, served to merely confuse the clients. Disclosures for the most part have a root in very logical reasoning. Unfortunately we are being crippled by such vast amounts of disclosures. It seems as if there is no such thing as person responsibility from the clients anymore. Most if not all of the regulations are made to protect the client but I am not sure that they accomplish this. The amounts of disclosures have become so overwhelming that it takes hours of time to explain not only the investment basics but also explain the various disclosures. Most of my clients get so confused that they tend to ignore the information that I give them. I am fearful that this newest disclosure will have an unintended effect of limiting greatly the amount of choices that I will be able to offer my clients. This could affect nearly 400 of my firm’s clients. Expenses are a very important part of investments. Unfortunately this proposal misleads the investors into believing that the lowest cost products are the best and most suitable investments. I do not encourage high expense products but I do realize and try to explain to my clients the pros and cons of low expense and higher expense products. Ultimately the client will be the one who will pay the price by either limiting the choices available or via increased cost involved in processing all the paperwork. This proposal will merely serve to further confuse already confused investors. It would seem that the SEC’s efforts would be better served to attempt to incorporate all important fee information into the prospectus and attempt to simplify the prospectus in order to make this document easier to understand. Sincerely, Randall Young, Registered Representative |