Subject: File No. S7-06-04
From: Rodert D. Schlesinger, CLU
Affiliation: Retirement & Estate Plan Services
April 4, 2005
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
Re: SEC Proposal on Point of Sale and Confirmation Disclosures
Dear Mr. Katz:
I am a concerned financial professional who fears there could be negative impact for investors in general and for my clients specifically if the SECís proposal on point of sale and confirmation disclosures is enacted.
After four and a half years at a major brokerage, Shearson Lehman Hutton/Salomon Smith Barney, I became an independent financial advisor with Linsco/Private Ledger, where I have been for the past eleven years. In this environment, I feel I am able to offer my clients the most appropriate investment vehicles based on an unbiased assessment of their needs. The SEC point of sale disclosure system, as proposed, would have the unintended consequence of substantially limiting the broad universe of mutual funds and variable annuities that I am now able to offer my clients. This consequence could affect approximately eighty-five of my clients who currently invest in mutual funds.
Certainly cost is an important factor in any investment decision, but I believe this proposal misleads investors into believing that the lowest cost product is simply the most suitable versus encouraging investors to weigh all the relevant factors such as performance, adherence to a stated investment objective, turn-over and moreÖ
While the intentions of this proposal are honorable, I fear that that the net result will be that the individual investor is put at a disadvantage and will ultimately pay the added cost of implementation, either through increased fees or a limitation in the number of products and choices that they will have available to help them meet their financial goals..
The complexity of the proposal runs the risk of further confusing investors. Rather than adopt the current proposal, I would urge the SEC to re-focus its efforts on incorporating important fee information into the prospectus and in turn, creating a more user-friendly prospectus that would better aid investors in their decision making process. Perhaps something more similar to a qualified planís Summary Plan Description, which is designed to give the facts in a simple fashion and not to persuade participants in the manner a marketing piece would.
Thank you for your consideration, sir.
Rodert D. Schlesinger, CLU
Retirement & Estate Plan Services