Subject: File No. SR-NASD-2004-043
From: Colon Brown
Affiliation: Brown & Brown Securities, Inc.
September 10, 2004
RE: File Number SR-NASD-2004-043
To Whom It May Concern:
Brown & Brown Securities, Inc. supports the proposition of full disclosure regarding any investment opportunity, including all types of mutual funds and investment trusts. The proposed rule changes, however, appear to be limited to various quantative statistics rather than more important qualitative information. Such an emphasis on statistical information may appear to be informative. It is our opinion, however, that investors may already be burdened with too many statistics. Such information encourages investors to value the lowest cost provider when other somewhat higher cost providers may be more suitable selections.
It is our suggestion that the more important information involves the credentials and experience of the fundsí advisors, the investment disciplines they follow and the ethical standards they employ regarding the distribution of their shares. Such information should be made available in reasonably large print and understandable language. It is our contention that the combination of capable advisors, well conceived investment disciplines, and evidence of ethical distribution procedures diminishes the need for a flood of potentially confusing statistics and short term performance information.