From: Troy DeLair
Jonathan G. Katz
I am a securities licensed insurance professional.
I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products seem to be a repetition of the safeguards already in place.
Mutual fund and variable annuity prospectuses, which are reviewed by the SEC, already discuss the fees, risks and expenses associated with the purchase of these products.
If you feel there are additional issues regarding the contents of the prospectus, it seems it would be easier for the SEC, companies and representatives to implement changes to the prospectus itself rather than creating a new but similar outline of the fees and charges.
Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus, create confusion as yet another document is thrown into the mix and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus.
A disclosure that only discusses an investment's fees and expenses will lead people to focus on the investment's costs rather than its overall returns and benefits. After all, which is the better investment -- one with low costs and a net annual return of 2 percent, or an investment with twice the expenses and a net annual return of 6 percent?
With the baby boom demographic, there is now (more than ever) a need for individuals to invest in a well diversified portfolio. A form that highlights only the negative points of an investment (the fees) will curtail the publics need to invest appropriately for the future at a time it is needed the most.
For these reasons, I urge the NASD to withdraw the proposed rule.
Thank you for your consideration of my views on this matter.