From: Jeff Shamis
Jonathan G. Katz
I''m a fee-based financial planner who recommends mutual funds & variable insurance/annuity products to my clients when appropriate to implement/maintain their financial plans.
I'm writing to urge you withdraw the proposed disclosure requirements as proposed by the SEC (re sales of mutual funds & variable products) as redundant with existing requirements and therefore burdensome, confusing, costly, and unnecessary.
Prospectuses for these products already discuss relevant fees, risks and expenses as required. Regulators & industry have strived to simplify prospectuses in recent years; inadequacies (if any) should be addressed in the prospectuses, rather than developing new/additional materials.
Requiring a disclosure that focuses on investment fees & expenses without any mention of possible benefits of the product(s) may be as misleading to the investing public as it would be to discuss returns & performance without mentioning fees & expenses (& risks).
In summary, I urge you to withdraw the proposed rule.
Thanks for considering my views.
Jeff D. Shamis