From: Dean Ripley |
Dean Ripley Jonathan G. Katz Jonathan Katz: The proposed regulation changes on fee disclosure in SEC and NASD supervised transactions is credible in its intent, but dangerously ignores the practical application of the changes. We live in a society that is literally starved for good investment guidance. People constantly are bombarded with the marketing engine that drives them to make savings and investment decisions based on information provided to drive viewership and subscription sales, rather than the pursuit of sound financial management. To create yet another potential stumbling block for the public to encounter as a deterrent to getting help with the most important personal issue beyond their health would serve only to handicap the same constituents you are intending to protect. If you feel that fee disclosure is being abused, the remedy is not to be found in industry wide regulation, but rather in individual firm and practitioner punishment for transgressions of existing standards. The fines recently leveled at some firms and individuals for violations on B Share funds abuses are a move in the right direction. Good practitioners are already disclosing fees, and increasing regulation for those "doing it right" pushes us closer to deciding it isn't worth the hassle to get the job done. It also pushes the willing investor away from getting better advice and toward doing it themselves-something that history has proven is not in their best interest. Please consider these thoughts as you determine a course of action. Sincerely, Dean J. Ripley |