September 10, 2004
I am writing to comment on the SEC rule which represents flagrant disregard for a public policy which puts the public's financial interests in a primary position. The SEC's rule allowing large financial institutions to essentially misrepresent the services they offer provides a venue of "a wolf in sheeps clothing" for these firms and their sales representatives. This is especially egregious given the the recent history of institutional malfeasance that has occured in our financial market environment. Not only is this morally and ethically indefensible, it is bad social public policy. It supports a context of eroding whatever confidence may be left in the integrity of our financial markets. As the SEC is well aware, it is only by having a playing field where participants have a high degree of trust in the system that allows the continued formation of capital essential for continued investment and expansion of the economy.
Please reconsider this poorly crafted policy position. The requirement of full disclosure allows prospective investors the opportunity to better assess the fuller spectrum of risks they assume when investing and making financial decisions. This should be the foundation of a well developed, efficient, and ethical capital market system.