From: Paul Zietlow
Jonathan G. Katz
I sell variable products and 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 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 and create confusion.
Disclosure that only discusses investment fees and expenses will lead people to focus on the investment's costs rather than its overall returns.
Investment with the lowest costs may not be the best investment for the investor.
For these reasons and many more, I urge the NASD withdraw the proposed rule.