From: Steven R. Gleason
As a small broker dealer with less than 20 brokers, this proposal would create a financial and operation hardship. To have to produce and maintain and distribute at the time of presentation instead of sale would create unnecessary disclosure. The proposed requirement of new disclosure materials would essentially duplicate requirements already in place regarding the contents and delivery of the mutual fund or variable product's prospectus. The prospectus, which is reviewed by the SEC, already discusses the fees, risks and expenses associated with the product. Requiring a separate, duplicative document would run counter to the efforts of the SEC over the past decade to simplify the contents of prospectuses. Instead, regulatory efforts should be focused on getting consumers to carefully read the prospectus they already receive.
In practice, with the proposed rule, when I sit with a prospect and review investment options, I normally review and discuss all major investment types and the differences between them such as banks products, gov't bonds, non govt bonds, stocks, annuities, mutual funds. And to be required to disclosure the potential fees and expenses on all these products at that point in a meeting would be to cumbersome and confuse the client to the point of not being able to make decision.
I would be in favor of a point of sale disclosure when a product is purchased, a one page consolidated disclosure that list the actual fees:
Type of share class and the actual fee schedule, fund M&A, any bonus commission paid to the broker (but not standard commission). For annuities, list the Annuity M&A, list purchased benefits expense, the underlying fund M&A and any sales charge or deferred sales charge schedule. This would provide a consolidated point of sale disclosure that list the actual expense.File No. S7-06-04"Steven Gleason
New Horizons Asset Management Group, LLC
11 Racquet Rd. Suite 2
Newburgh, NY 12550