From: Joseph F. Marshall
Although I understand and agree with the concept of consumer disclosure and education regarding their investments, I cannot believe that the SEC is seriously considering this new proposal of disclosure as a viable option. The burden of cost far exceeds any benefit that would be experienced by either the investor/consumer, or any regulatory group responsible for oversight. I do not see the benefit from this proposed mandate, nor do I see any plans for, or data testing measures to determine the success of this very expensive point of sales disclosure rules.
As I see it, it has not yet been determined as to who will be responsible for the costs generated by these proposed rule changes. Since the responsibility will ultimately fall to either Brokerage Firms or Fund Families, thus ultimately the consumer, I think that it would be wise to consider the overall ramifications of this decision vs. the benefits to the consumer. I feel the investor/consumer has a principle responsibility to take a more proactive role in the design and management of their investments. Far too often the investor does not take advantage of the point of sales materials and disclosure information already available. This begs the question. Will the consumer/investor (the ultimate reason for these actions) be willing to pay for these proposed changes? and most important, Will they benefit in proportion to the cost?
I ask that you shelve this proposal as an overly expensive option and continue to improve the rules required of the Brokerage Firms, their Repís, Fund families, and understand that you can only protect the consumer that is willing to be protected. I would appreciate and look forward to your response.
Joseph F. Marshall