From: Robert L. Erkel
To the SEC in reference to the proposed additional disclosure form:
I just want to comment that I've been in the industry since the later 80's and the prospectus does a nice job of laying out the cost and fee associated with mutual funds and variable annuities. Instead of creating another layer of administration and bureaucracy, I would suggest simplifying the prospectuses or requiring something in the prospectus that puts that information up front if you need it presented more clearly. Many times when a client has a problem or issue, we quickly want to come to a system wide change to deal with that one client's problem or few clients' problems. Then we create a mountain of paperwork to deal with what might be an issue for a small number of people. I would suggest you look at the long term impact of these changes and find a more streamlined way to use current prospectuses, which already require to disclose this information.
If you have additional questions, please contact me.
Life, NMIS (Series 7, General Securities Representative)
Robert L. Erkel, CLU, ChFC, CFP™
Northwestern Mutual Financial Network is the marketing name for the sales and distribution arm of The Northwestern Mutual Life Insurance Company and its subsidiaries and affiliates. Agent, The Northwestern Mutual Life Insurance Company (Northwestern Mutual), Milwaukee, WI, life insurance, annuities and disability income insurance, Timothy John Bohannon, General Agent. Northwestern Long Term Care Insurance Company (NLTC), Milwaukee, WI, long-term care insurance. NLTC is a subsidiary of Northwestern Mutual. Registered Representative, Northwestern Mutual Investment Services, LLC, (NMIS) 1400 Corporate Center Curve, Suite 200, Eagan, MN 55121 (651-456-9446), securities transactions and brokerage services. NMIS is a wholly-owned company of Northwestern Mutual and is a member of the NASD and SIPC. Northwestern Mutual is not a broker-dealer. There may be instances when this agent represents insurance companies in addition to Northwestern Mutual or NLTC.