March 16, 2004
I commend the SEC on its decision to improve transparency in the brokerage business.
As an individual investor, we are often the last to benefit and the first to feel the brunt of brokerage fees, conflicts of interests, and alliances.
I would urge the SEC to require brokerages to use such a standardized format to convey to the public their fees in much the same standardized way that credit cards are required to spell out their terms. The standards should include font size, layout, and the criteria for disclosing conflicts of interest and fees.
In the area where conflicts are described, the nature of the conflict should be clearly spelled out. Many in the industry are adept at changing the name of the company, or forming a holding company with an inoccuous name, so that disclosures will seem to be less conflicting. I would urge the SEC to require brokerages to describe the company / conflict in a few sentences and to elucidate the nature of the conflict.
Fees should also be listed in this way. The addition of fees should trigger an addendum to the sharholders using the same standardized format. One should not have to hunt through a prospectus to get the information.
I also think that the SEC should solicit the help of the AARP and AAII to create this standardized format for disclosure.
Thank you for giving me the opportunity to comment, and please contact me if you would like to follow up.