From: James H. Duren
Dear Mr. Katz:
The proposed change in the disclosure of fees in the "Proposed SEC Rule on Disclosure" is a redundant recommendation that will add yet another layer of duplication. We already leave the client more disclosure information (prospectus) than they will ever read.
We are required to complete supplemental disclosure forms with our Broker/Dealer that again duplicates information in the prospectus, including disclosure of all fees. I think this proposed new regulation is unnecessary and will end up only having one more form for a client to have explained to them.
Enough is enough! Duplications of the same information is now past the point of reasonable, and this is just "piling on", in my opinion. I have been a Registered Representative with the NASD for 33 years, and I have seen us go from a one page application with one signature, to 20+ page applications and supplemental disclosure forms requiring as many as 12 signatures just to invest in a $500 Mutual Fund. Where does it end?
James H. Duren