From: James McPartland
Jonathan G. Katz
Please understand that I am writing to you as a consumer first, an advisor second, and a licensed insurance professional and variable products salesperson, last.
I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers.
Mutual fund and variable annuity prospectuses, which are reviewed by the SEC, already discuss the fees, risks and expenses associated with the purchase of these products. Very recently, in 2002, the SEC took steps to simplify the contents of the prospectus. If you feel there are additional issues regarding the contents of the prospectus, focus your efforts on further revisions to the prospectus requirements; if you still believe consumers should be given a "one-pager," the appropriate document would be the table of fees and expenses found in every prospectus. Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus, create confusion as yet another document is thrown into the mix, and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus.
What these proposed disclosure requirements will do is encourage those who feel they should simply spend their money, instead of saving and/or investing it. Any excuse to not save makes it easier to justify the concept of live for today.
Well, if the recent study by the Harvard Law School described in an article titled 'MarketWatch: Illness and Injury As Contributors to Bankruptcy' is accurate, the average amount of medical Bills that led to Bankruptcy for those interviewed was just $11,800! I would say that means we don't need more excuses to not save and invest! We need more encouragement to build up that emergency fund, and we need it now. the proposed reulations would simply add to the obstacles for an average consumer to save.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
James J. McPartland