Subject: File No. S7-06-04
From: dan keppel

March 17, 2004

Form to advise client in advance looks good
I would add the amount lost for B shares sale for each year. I assume you will use same format for annuities which have surrender charges and annual charges also.
On all forms, you need to have the client and broker initial and date the fact they have shown this disclosure. When I ran the operations at Thomson McKinnon Insurance and Dime Agency, we had every annuity and mutual fund sale accompanied by a disclosure signed and dated by both parties. It listed the name and type of security, guarantee period 1, 3, 5, rate, variable sub account, surrender backload period and percentage, free withdrawal terms, annual fees, other charges, break point levels, and statement to client understanding of same.
I would add that clients had trouble making requests to break the trade if we had this form in the file. Brokers were not paid until we had the form.
Glad to see SEC doing this.