From: Robert F. Entigar
Jonathan G. Katz
Ref: SEC Proposal on Point of Sale and Confirmation Disclosures
Dear Mr. Katz:
I have been an investor for the past 25 years and my recently deceased father had been one for a good fifteen to twenty years beyond that. When I became a financial professional eleven years ago, I made a solemn promise to myself to always provide my clients with the utmost of moral and ethical treatment, just as I'd wanted to have for myself and my father.
I have done so and have never compromised what is in my clients' best interest. Over the time of my involvement in this profession there have been some high-profile disturbing revelations and additions of rules and regulations to address them and potential others. While these additions have made the work of financial professionals more cumbersome, I believe, for the most part, they've been worthwhile additions.
I do not feel the referenced proposal on Point of Sale and Confirmation Disclosures fits this category and believe it will negatively impact not only the financial professional, but his client base as well. There will, undoubtedly, be costs of implementation to be born by the financial professional and the individual investor. There will be added complexity causing confusion and limitation and/or poor decisions on the part of both parties. And the upside, if there is one, to the implementation will fall far short of the downside.
I ask that the SEC mandate, and audit if necessary, that disclosure of the presently available material be full and effective, as I believe I provide for all of my relationships. If the system of prospectuses is too cumbersome, then revise it to be less so. Do not add restrictions and/or requirements that will not benefit the original investor.
Robert F. Entigar