From: Donald R. Burkall, CLU, ChFC |
All mutual funds and variable annuity prospectuses ( which are reviewed by the SEC) already disclose the fees, risk and expenses associated with purchasing these investment products. In fact, in the year 2002 the SEC took steps to simplify the contents on this prospectus. Since this information is already covered in the existing prospectus that all consumers must receive before purchasing investment products, I can't for the life of me understand why requiring a new separate disclosure document at the point of sale in confirmation would provide any additional information or protection for consumers. If the advisor is not providing the prospectus which includes this information to consumers, please spend your time prosecuting those who are not following the current rules but lets not add more layers and more layers of needless information and rules that just hinders the whole process for all of the sales people and make it so much more confusing for consumers. It becomes more and more difficult for consumers to understand anything that is being presented to them. Every layer of complexity just drives the consumer to depend more and more on the advice of an advisor rather than trying to read and understand all of the added paperwork that the SEC continues to force us to generate for them. I certainly believe that appropriate disclosure must be done to protect the consumer but duplicate and over whelming paperwork certainly does not make it easier or better for consumers to accumulate money for their future. For these reasons I urge NASD to withdraw the new proposed rule. Best regards, Donald R. Burkall, CLU, ChFC Donald R. Burkall, CLU, ChFC |