From: Susan C. Fewell
I have been a licensed insurance professional and variable products salesperson for almost 20 years. my u-4 is very "clean" The proposed "new"disclosure requirements ,regarding the sale of mutual funds and variable products by the SEC is a prime example of "beating a dead horse" The industry is already covered with disclosure after disclosure, with absolutely no impact on the bottom line which I assume is to protect the investor. This type of proposal would only serve as to "discourage" the investor and bring a "negative and insulting feel, to the entire transaction . First by the redundancy of repeating information already available in the prospectus thus setting off an alarm in the clients thought process that something is wrong. Second by further destroying the integrity of the entire industry already rocked by several unethical scandals by a few major brokerage firms .
This proposal is unwarranted and will serve as the death of the small independent firms who do not have the hundreds of thousands of dollars to "swoon" the investors with advertising.
The large Merrill's and such will survive and others like myself will be left by the way side.
The overall "clean up" of the investment industry should be an on going process with both parties to the actual transactions being held responsible. This proposal will not help one investor but will plant seeds that most certainly will lead to more complaints in the future as you have insinuated a problem before the transaction was even completed. No Government should take full responsibility for influencing individuals decisions by offering information , that has legally been provided, in a "new" and altered presentation
I personally applaud the work that is being done and think it is long over do but if anything needs to be "reworked" in the process, then certainly it should be the prospectuses.
I urge the NASD to withdraw the proposed rule and to focus on enforcing the current laws and regulations, continue investor education and realize that the investor must take responsibility for their decisions if made after they have been provided information in compliance.
Your authority and governance is respected and appreciated.