From: David M. Edwards
I have been a licensed insurance and variable product salesman for more that 20 years. I am writing regarding your proposal to add another layer of disclosure requirements to the sale of mutual funds and variable products (life and annuities).
As you are aware, mutual funds and variable products prospectuses already contain the "newly recommended" fees and expenses disclosures in detail. The SEC has recently taken steps to assure that potential purchasers can understand these fees, and the applications they complete acknowledge the receipt of the prospectus and therefore, the disclosures. An additional sheet of paper with the disclosures of the fees, risks and expenses of these products without reference to the benefits, comparisons to alternative investments and their respective fees and performance histories provides no additional information to the consumer.
I urge the NASD to withdraw this redundant and unnecessary proposal.
David M. Edwards, LUTCF