From: Nicholas A. Smith
Jonathan G. Katz
Re: SEC Proposal on Point of Sale and Confirmation Disclosures
Dear Mr. Katz:
I have concern about the SECís proposal regarding point of sale and confirmation disclosures for investors. I am a financial professional and recognize the negative impact this proposal would have on my investors.
Over 1000 of my mutual fund investors would be limited in their choices of mutual funds by this proposal. This proposal would also point out the lowest cost product but ignore other factors that go into selecting a mutual fund (i.e. suitability). My variable annuity investors would similarly be restricted to a much smaller universe of choices in the VA market.
I am afraid that in the end it will be the individual investor who will suffer the added cost of implementing this proposal, either through increased fees or a limited selection of products offered.
The complexity of the proposal runs the risk of further confusing investors. I strongly suggest that the SEC instead look more to improving efforts at explaining important fee information found in the prospectus as well as simplifying and condensing such. This is how investors could be better served in my professional opinion.
Thank you for listening.
Nicholas A. Smith