From: George S. Slusher
March 30, 2005
Jonathan G. Katz
I am an insurance agent in Floyd Virginia and also sell variable products. I believe that the new disclosure requirements the SEC is proposing are unnecessary and merely duplicate existing disclosures already contained in the prospectuses. I do not see how consumers will be better served by yet another document that will given to them at the point of sale, especially when it duplicates information already provided.
The current prospectuses which we provide already discuss fees, risks, and expenses associated with the products. The SEC reviews the prospectuses. As I understand it, in 2002 the SEC simplied the requirements for the contents of prospectuses. If there are additional issues here that need to be addressed, why not see if further revisions in the prospectus are in order before ordering a separate document to be used. Requiring a new form, in my opinion, will just create more confusion at the point of the sale, and reduce the likelihood that consumers will read the prospectus. The prospectus is by far the most important source of information on the product that is being purchased.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
George S. Slusher