From: Steve Hofer
Jonathan G. Katz
Dear Mr. Katz,
I have been a financial advisor for 20 years. Having a client become more informed prior to the purchase of a financial investment is a good thing. My experience tells me that the average client rarely reads the prospectus because the regulators have required far too much detail. Very few Americans, when buying a house, read all the closing documents for the same reason.
If our mutual goal is to inform the investor, we must do it with the consideration of the amount of paper we require, the added expenses it will generate, and the simplicity of the disclosures. Otherwise the entire exercise becomes counter productive.
I have always felt that most of these discloser requirements fall under the category of CYA. If a client goes to court we can all (the SEC, the mutual fund company, the broker dealer, and the financial advisor) pull out the paper the poor client signed and say, “don’t look at me”.
Please be careful to not make things worse in an effort to expand the CYA documentation. Please keep the clients best interests in mind. Some of these proposals appear to be aimed more at a belief by the SEC that the financial survives industry are a bunch of loose cannons, making to much money ripping the poor public off. This is not the way to fix the problem if it exists.