The following Letter Type L, or variations thereof, was submitted by individuals or entities.
Letter Type L:
Securities and Exchange Commission
Dear Securities and Exchange Commission:
I urge you to withdraw your Point-of-Sale and Confirmation initiative. The delivery of redundant cost information in a point-of -sale document competes with the SECís efforts to streamline disclosure, and may unwittingly discourage consumers from reading the primary information documentóthe prospectus.
The recently upgraded prospectus requirements for variable life insurance and variable annuities already provides plain-English disclosure about expenses in a clear fee table. More disclosure is not better disclosure.
Many broker-dealers and their salespersons will be unable to generate the individualized cost information required in the proposal. Even worse, the proposal unnecessarily increases broker-dealersí legal liability for inadvertently preparing inaccurate information.
A far better solution would be to point customers to the prospectus fee table and to keep disclosure in a single document rather than separate, redundant documents. Another alternative would be to simply require broker-dealers to deliver the fee table instead of a new, redundant point-of-sale document.
The life insurance industry supports full disclosure, informed decision making, and comparison shopping. The prospectus effectively achieves this goal. The point-of sale document does not. The proposal has demonstrated neither the need for the proposed requirements nor that they will achieve their purpose. The initiative should be dropped.