Subject: File No. S7-06-04
From: Wally Schmieder, CLU, ChFC
March 30, 2005
As financial services representative that makes a career at helping people make choices to help them achieve their financial goals I am opposed to more disclosure that doesn't provide any new information. We are one of the most highly regulated industries and yet there always seem to be more requirements that don't help the consumer any more than what companies already require, plus the demands of ethical behavior we put on ourselves. Consumers aren't helped either since we have more printed paper to hand out than any other industry for a simple sale or a complex sale. A better idea I would think, that anyone selling mutual funds or variable products should be required to belong to one of the industry professional organizations for an additional level of oversight and continuing education.
I'm afraid we're always trying to protect the public from unethical marketers but it seems they will still continue bad practices no matter what we do. Time and money is better spent in overseeing the current regulations and practices. So I suggest being more practical in your approach. Maybe change the prospectus requirements that already are required, and have a summary of cost but also benefits of mutual funds and variable products in a one page summary. Focusing on cost alone does not make one product better or worse, each client's situation will help determine this any way.
I would urge you to withdraw this proposal and reconsider alternatives to help all of us better serve the public in an ethical an unbiased manner.
Thank you for the opportunity to express my thoughts.
Wally Schmieder, CLU, ChFC
Principal Financial Group-St. Louis Business Center A076
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