The following Letter Type O, or variations thereof, was submitted by individuals or entities.
Letter Type O:
Jonathan G. Katz
Re: File No. S7-06-04
To Whom It May Concern,
I am writing to you in regards to the new disclosure requirements contained in the new SEC proposal regarding the sale of mutual funds and variable products. They are completely unnecessary, and will provide no meaningful additional protection to consumers.
Mutual fund and variable annuity prospectuses, which are reviewed by the SEC, already discuss fees, risks, and expenses that are associated with the purchases of these products. If the SEC feels that there is additional need for further clarification, that could be done easily through the prospectus.
You mentioned that your proposal would be one page document. I am sorry to say that every time you come out with one of these "one page" documents in a short time, they end up being multiple pages.
Today, our industry is inundated with forms that we have to have the clients sign every time they do any kind of a transaction with us. This is costing our industry, myself included, billions of dollars a year, serving little or no purpose to the client. Invariably, those fees are going to get passed down to the client.
The complete over emphasizing of fees and expenses will lead to people to focus on the investment cost rather that the overall net returns they may receive.
Today, every time a client comes into our office because of government and the press heavily emphasizing fees, that is all the client zeroes in on, secondary to what the return could be. We should be spending more time emphasizing what the returns could be after these fees rather than what these fees are.
While all these disclosures may sound fine to the government, we here in the field, work in the real world. We have to have rules and regulations that deal in the real world. Being inundated with all of these new forms, and constantly shifting and changing requirements, has become overly burdensome. It is almost a full time job just keeping up with all of the changing SEC/NASD requirements today.
Thank you for your attention to this matter.