March 16, 2004
I agree that having this information both before and after a purchase is important. I believe the before purchase disclosure is very important for inexperienced investors so that they can have the option of avoiding a potenetially costly mistake. However, I am concerned about the costs involved in generating and distributing the information. We seem to be in an environment of ever increasing costs in investing. It is unlikely that an investment firm will be willing to absorb these costs. Im sure they will be passed on to the investor. It needs to be determined if the costs of such a program are greater than the benefits.
I have some concerns about how the process will be implemented. I make 95 percent of my purchases on-line and expect buys and sells to be executed promptly. It isnt clear to me how the Point of Sale information could be prepared and delivered to me for my consideration in a time period equalling my expectations of when orders are to be filled.
Perhaps a waiver system could be put in place where after an initial purchase an experienced investor aware of the costs involved could execute a one time waiver with each investment firm he uses and be willing to accept just the after purchase report for all subsequent purchases.
If rules are going to be enacted that require the reporting of investment costs, then I feel all costs, specially trading costs for mutual funds, should be disclosed.