March 15, 2004
The proposed disclosure of fee information
is very appreciated. The forms however
provide too many numbers, it is also
difficult to understand terms such as
front-end sales and back-end sales.
Section A: Good format as is.
Section B: Replacing costs with percentages would
Potentially split into three items:
a Fees paid at time of asset purchase:
b Fees paid at time of asset sale:
-if sold within 1 year
-maximum fee if sold after 3 years or more
c Annual fees to own asset
-first year fee
Disclosing industry norm is good.
Section C D:
Two sections could be combined.
Section C information could be combined
into one number. A list of costs increases
the risk that any new fee will not be
mandated and will go undisclosed.
Discounts will already be factored into numbers
in section B. Consider removing.
Consider potentially adding requirement for providing
a URL to a page showing additional fee information
associated with the purchased asset. Similar
to how FCC requires telephone companies to
display their rates.