From: David G. Brouwer
I think that the rule is unduly burdensome, particularly from a compliance standpoint.
I understand and applaud the spirit of the rule, but not the detail.
Why not have every investor who purchases a prospectus item, sign a disclosure that the Investment Rep has discussed fees and commissions with the client prior to purchase and further that IR has shown the client the "fees & expense" portion of that prospectus.
Every client who currently purchases a Mutual fund from me, currently signs a disclosure that I have explained A/B/C share pricing and includes a breakpoint worksheet so that customer understands there are breakpoints involved with A share pricing.
If we took the idea of the proposed rule to the Automobile industry and made car dealers disclose every single bit of commission, rebate, profit margin at the manufacturer level, sales person level, dealership level, as well as the cost components of each part of the car such as the tire manufacturers markup as well as their R&D cost per tire so that the consumer could decide whether they wished the salesperson to take off the Goodyear tires that came with the car to replace with Bridgestone tires etc, etc.
I truly believe there still too many brokers in the industry who do not work in the clients best interest, either out of stupidity, greed, self-interest, poor training, unscrupulous management and several other reasons, but this rule is not the way to fix the problem.
David G Brouwer