From: Lesley Pinckard
Jonathan G. Katz
I am a licensed insurance professional and variable products salesperson.
The SEC's proposal regarding the sale of mutual funds and variable products are unnecessary, cumbersome and will provide no additional protection to consumers, only duplication.
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. Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus.
Also, it will do little to encourage (actually, will discourage) clients to read the most important source of information on the product -- the prospectus. Therefore, the SEC should focus its efforts on getting consumers to carefully read the prospectus they receive.
Finally, a disclosure that only discusses an investment's fees and expenses will mislead people by focusing on the investment's costs rather than its overall returns.
For these reasons, I urge the NASD withdraw the proposed rule.