March 5, 2004
re: proposed new mutual fund disclosures
1- The comment period is not long enough, please grant an additional 60 days to review and comment.
2- 12b1 fees should be continued. They are well disclosed in prospectuses and 3rd party sources such as Morningstar, and they are included in overall expense ratios which investors almost always consider. If eliminated, many investment professionals will stop servicing smaller clients and move larger clients to a fee-based account and replace the 12b1 charge with a higher RIA fee.
3- Transaction costs should be disclosed more fully. This is perhaps the most misleading aspect of fund sales and is almost entirely overlooked. Transaction costs can double or triple the cost to the shareholder and investors are not aware. Most investment professionals are not aware as the actual cost is buried in the statement of additional information which is seldom seen.
4- Disclosure is not a threat to our industry, over regulation is. Please make any new requirements simple. Credit card disclosures fit easily on a post card. Please keep it simple.
Thank you
Randy Nicholls