From: Seth J. Diener
I am a Series 7 licensed Financial Advisor. I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds.
A Mutual fund prospectus, which are reviewed by the SEC, already discuss the fees, risks and expenses associated with the purchase of these products. I thoroughly review the fees and expenses associated with each share class with EVERY client I have. I review the prospectus with a client both before and after the sale of a mutual fund.
I have met with many clients over the years who listen to people in the newspaper and on the television who hammer home low expenses and no-loads. I believe that it is extremely important for a mutual fund company to provide the absolute minimum in fees for the best returns possible. With that said, I have seen many people who have opted against incurring a load, because of what they read or heard on t.v., and as a result, incur significant loses due to trying to be their own advisor. It is a shame that any of these people should have to lose any money. If I could offer my advice for free and still be able to feed my children I would.
If you should chose to have a separate statement about fees (as a disadvantage) you should also have a separate statement which outlines returns of advisor recommendations vs. people doing it themselves (as an advantage). This is standard contractual language, Offer and Consideration. This should be a requirement to anyone who opens a no-load or non-advisor brokerage account as well as to the people who open accounts with the guidance of a financial advisor.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this very important matter.
Seth J. Diener