Subject: File No. S7-06-04
From: Harry H. Branning, President & CEO
Affiliation: Branning Financial Group, LLC
Mr. Jonathan G.Katz,Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Dear Mr. Katz:
There's a great deal of rhetoric on these new proposals that may seem self interested in nature, but, as a 30 year veteran of this industry, I believe that some regulations may well have unintended consequences and miss their true target.
I believe investor's do need disclosure of fees and commissions, but it should be clear that price is not the only determinant in a successful advisor/client relationship. Too much paperwork causes confusion and a reluctance to do anything and may result in an investor doing nothing when that is the worst thing for them to do. I believe all investors need to work with their advisors to set realistic goals AND these goals/objectives should be tracked/monitored on a quarterly basis on ALL client month end statements. From experience I know clients feel much better if they can see that their goals are being realized (or not and changes are needed). and have a means to see their progress.
These mutual fund proposals appear to have the real potential of creating an unbelievable morass of paperwork that will probably not help the client know if they are achieving their goals or objectives, but will focus too much on near term costs.
In the 1990s we saw many individual clients open accounts at discount firms and trade stocks and bonds AT A CHEAP PRICE. Generally these investors fared poorly as they traded too much and reacted too quickly too "news." They certainly had saved money short term, but lost their way toward achieving meaningful financial goals. All firms need to encourage clients to be investors with a long term focus and help them monitor their progress. This type of disclosure will better aid investors as advisors (or clients themselves) will be accountable for their performance (which will be affected by costs) and this transparency will give clients the disclosure they need to make the most important decision. Are they achieving their goals with their present course of action with their current advisor (or themselves).
Do not rely too much on price disclosure and undue paperwork to help investors achieve their goals. Performance disclosure along with reasonable other disclosures is most important.
Harry Hayes Branning
Harry H. Branning
President & CEO
Branning Financial Group, LLC
800 238 7795