January 8, 2008
A Summary Prospectus is an EXCELLENT proposal. Most investors do NOT read prospectuses today since they are a)written with too much legal lingo and b) way too long with very little meaningful information. Cost savings is secondary. Greater investor understanding is the main objective.
A few specific comments:
1) When describing the "investment strategies" employed, the section should not only describe what COULD be done but also what the fund TYPICALLY does. The fund CAN invest internationally or go short. But what does the fund really do? Comments like this from AIVSX are NOT helpful "The fund's investments are limited to securities of companies that are included on its eligible list."
2) There needs to be some flexibility for funds to customize the short version. The approaches of funds are so different that it may be too hard to find a one size fits all format.
3) On the return/risk section, better comparison to benchmarks is desirable. Has the fund historically increased or decreased risk compared to its benchmark? Appropriate benchmarks should be shown blended benchmarks could be used when appropriate(e.g. 70% SP 500 + 30% DJ Aggregate Bond Index). A good addition might also be to show risk (e.g. standard deviation) compared to the benchmark.
4) Mutliple fund classes need to be included in the same document. It is important to be able to compare expenses and commissions. However, different funds (not share classes) should not be lumped into the same document. There may need to be some exceptions for "lifestyle" funds where the only investment difference is asset allocation. Different funds have different objectives and risks, and thus they need to be separate.
5) Redemption fees and restrictions need to be more clear. If a certain number or timing of transactions can cause restrictions, that section should be clear and concise.
6) Yes, ticker symbols should be used to clarify the investment and share class. Prose is not sufficient.
7) Yes electronic delivery of the summary prospectus should be allowed. This will increase the number of investors that actually read the prospectus. Mandatory delivery by the fund company (or custodian) at two times: at time of initial purchase and annually thereafter. Choice of 2 delivery methods: paper via US postal mail and e-mail. The investor chooses, default is paper.
8) Commission products should be called out more clearly as such. The load and trailing commissions should be clearly identified.