April 1, 2005
The SEC has proposed new rules File number S7-06-04 that will require broker/dealers to provide customers with targeted information, at the point of sale and in transaction confirmation, regarding the costs and conflicts of interest that arise from the distribution of mutual fund shares, 529 college savings plan interests, and variable insurance products.
The adoption of these proposed rules will have substantial unintended consequences for independent broker/dealers and registered representatives such as myself. Of primary concern is that complying with the proposed rules - principally the creation and maintenance of the point of sale disclosure - will be so extremely burdensome and costly that broker/dealers will be forced to limit significantly the number of Covered Securities approved for sale. This in turn will limit the availability of suitable products to design financial soltions for my clients, the investing public.
Because of the timing on the publication of this proposal I have not had a substantial opportunity to review the proposal and would like the comment period extended for an additional 30 days.
Edward C. Skelly, ChFC, RFC