March 16, 2004
I have my own investment portfolio and I have worked as a broker/for a broker. So I have 2 perspectives.
As an investor I have had to really dig hard to find out ALL the fees associated with shares of mutual funds to the point that I dont have any funds that are not up front about their fees. I was particularly disturbed with the management of a 403B. They had fees that were NEVER disclosed until I badgered the agent and told him I knew they existed
The new forms provide information in a way that is friendly to the individual investor. They should be provided IN the prospectus PRIOR to the purchase of the investment and the client should sign that they have seen the prospectus and the COSTS of the fund. I dont think more paper or an additional form is more helpful or necessary. I usually read the fees section for every prospectus I receive along with the returns.
As a broker, this form would make me crazy. There are already so many pieces of paper that customers feel like they are buying a house when they are investing 2,000. This additional form would not encourage them to participate in investing. It looks similar to a disclosure form akin to used car sales.
The biggest problem for small investors is getting them to invest at all. Clear disclosure in the prospectus would speak to making the costs of investing more clear. Also it would not add to a process that is already too long
Please do not use a new form. Instead enhance the prospectus process that is already in place.