From: Lawrence J. Donna
I OBJECT to the new "Point of Sale and Confirmation Disclosures" the SEC is proposing.
When I open a new account, let's assume they were transferring a previous account from another broker dealer, the client must receive and sign the following:
1. New Account Application (3 pages)
2. Financial Institution Disclosure (1 page) 3. ACAT form (3 pages) 4. Switch Letter and disclosure (2 pages) 5. Breakpoint disclosure worksheet (2 pages) 6. Prospectus receipt (2 pages)
Almost half of the required paperwork is one form of a disclosure. Now you want to add another one? How many pages will this be?
What good is mutual fund or annuity prospectus when you want Broker Dealers to regurgitate most of the information in the form of disclosures?
This is getting ridiculous. Is your aim to confuse individual investors?
This proposed disclosure is best suited to be included in a prospectus.
THE CLIENT IS REQUIRED TO RECEIVE A PROSPECTUS AND SIGN A FORM CONFIRMING ITS RECEIPT!
Please let us do our jobs in an efficient manner. Instead or proposing new regulations and disclosures, why don't you enforce heavier penalties on those who do not follow the current regulations?
Lawrence J. Donna