From: G. Wilson
The proposal's requirement of new disclosure materials would essentially duplicate requirements already in place regarding the contents and delivery of the mutual fund or variable product's prospectus.
The prospectus, which is reviewed by the SEC, already discusses the fees, risks and expenses associated with the product. Requiring a separate, duplicative document would run counter to the efforts of the SEC over the past decade to simplify the contents of prospectuses.
Instead, regulatory efforts should be focused on getting prospectus to be more readable by the general public.