From: D'Cater Joseph
Jonathan G. Katz
I suggest that before you pile yet another disclosure form on the public, you consider the desensitization all this paperwork might cause.
The disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are already included in the prospectus and will provide no meaningful additional protection to consumers.
Mutual fund and variable annuity prospectuses already discuss the fees, risks and expenses associated with the purchase of these products. A disclosure that discusses an investment's fees and expenses but omits risks and objectives will lead people to focus only on the investment's costs to the exclusion of relevance to their financial plan.
If I felt this form would provide something that the prospectus does not, I would understand the logic. But this seems like an unnecessary effort.
Thank you for your consideration of my views on this matter.