From: William Alan Rock
William Alan Rock
Jonathan G. Katz
I am a licensed financial services professional with 16 years of experience in the business. I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers.
Several actions have been inacted into law over the recent past regarding full disclosure of fees, risk and expenses associated with investment products. In addition, the SEC has taken strides to simplify the sharing of such information in an effort to encourage the consumers of investment products to become more familiar with these products.
The information you wish to share with the consumers is already available in very clear,concise fashion through the prospectus and included in tables and graphs depicting the costs associated with them. Requiring a new, separate disclosure document at the point of sale and at confirmation would duplicate information already found in the prospectus, create confusion as yet another document is thrown into the mix, and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus. Instead, the SEC should focus its efforts on getting consumers to carefully read the prospectus they receive.
Finally, a disclosure that only discusses an investment's fees and expenses will lead people to focus primarily on the investment's costs rather than its overall returns. Focusing entirely on costs as opposed to a balance of costs and returns would further discourage personal investment and savings for retirement and place even more pressure on an already strapped governement system for retirement purposes. American investors do not need to take a step backward, they need to move forward and develop the discipline to save even more.
For these reasons, I urge the NASD withdraw the proposed rule.
Thank you for your consideration of my views on this matter.
W. Alan Rck