April 1, 2005
I applaud the use of a concise, easy to understand form which will cover pertinent details of the mutual funds recommended to clients. However, is it really necessary to make it an additional document? Couldnt the information be listed in the front of the prospectus? Clients are already complaining about the abundance of paperwork that we provide to them, and adding another piece of paper to this mix probably wont help the situation.
That said, as a small Broker/Dealer firm I believe that your proposal to force the use of the internet to provide this information is creating a disservice to both the firms and the clients. First, you assume that most clients want to use the internet to obtain this information -- or that they would actually take the time, and have the resources, to access it. While there are certainly some people who would welcome that opportunity, not all have access or the ability to do so .......thereby defeating the purpose.
Many smaller Broker/Dealers and Investment Advisors simply do not have the personnel required to implement and provide upkeep for internet services such as those which you are recommending. Therefore, the clients would ultimately pay the price because firms would need to limit their choices in order to maintain information on their website -- forcing clients to choose from a smaller selection of funds.
Again, it appears that the many are paying for the sins of the few. Larger Broker/Dealers are receiving additional payments from the Mutual Fund families -- smaller firms generally do not. Its time that we hold those few larger firms accountable, rather than imposing extra work, costs and restrictions on everyone.
Yes, the overview document is helpful - and I would welcome the opportunity to offer it to our clients as a part of the prospectus. If the regulators deem it necessary, we could create our own internal stamp that would be placed on the document to answer the two recommended questions-- Are we receiving additional funds from the companies, and Are we paying our brokers additional monies to sell these funds? However, it should be noted that inclusion of these questions implies that the regulators APPROVE of these situations.
One final thought...........
Individuals who purchase mutual funds directly from the fund family without the assistance of a broker/dealer are not offered a discount -- the sales charge remains in effect even though the fund isnt paying a Broker/Dealer for the sales. Should the funds have to indicate that they are retaining the sales charges, and that the customer is not offered a discount even though they are not using the services of an advisor?