April 1, 2005
I have grave concerns about the proposed point-of-sale disclosure. As it is, clients complain about the volume of material they must receive. Many of them, I fear, do not read the prospectus and other disclosure documents precisely because of their volume.
The SEC would be much better advised to truly simplify the prospectus. Shift excess information to a readily-available SAI and encourage the prosectus to be read, not discarded or simply filed.
The new rules shift the burden to those who distribute, rather than manufacture, investment products. Because of the costs involved, especially to smaller broker-dealers, I believe their consequence would be to narrow choice among investors. If the goal is a well-informed investor being able to make wise investment choices, adoption of this rule as constituted would be a step in the wrong direction.