From: Steven W. Gaito
Re: SEC Proposal on Point of Sale and Confirmation Disclosures Dear Mr. Katz:
As an independent financial professional, I am concerned about the potential negative impact that the SEC's proposal on point of sale and confirmation disclosures will have for my clients.
One of the reasons I am independent is to be able to offer my clients the most appropriate investment vehicles based on an unbiased assessment of their needs. The SEC point of sale disclosure system, as proposed, would have the unintended consequence of substantially limiting the broad universe of mutual funds that I am now able to offer my clients.
Furthermore, while cost is an important factor in any investment decision, this proposal misleads investors into believing that the lowest cost product is the most suitable versus encouraging investors to weigh all factors of suitability. I agree that there are some investments that have expenses that are extreme, so why not focus on cleaning them up and allow me to serve my clients with the full spectrum of appropriate investments.
I fear that in the end, it will be the individual investor who will ultimately pay the added cost of implementing this proposal, either through increased fees or a limitation in the number of products offered.
Investments already have too many confusing documents and the complexity of the proposal runs the risk of further confusing investors. Rather than adopt the current proposal, I would urge the SEC to re-focus its efforts on incorporating important fee information into the prospectus and in turn, creating a more user-friendly prospectus that would better aid investors in their decision making process.
Steven W. Gaito