April 4, 2004
I think the new rules you are proposing regarding disclosure about fees and expenses are wonderful Please follow through and implement these rules they are a much need help to investors. My only suggestions would be that in both the confirmation and point of sale forms there be a section for a TOTAL of expected fees and expenses in both dollars and as a percentage out of the monies invested. This would give the investor a quick bottom line assessment of how much money is taken off the top of their investment dollar.
I am assuming that the on the back of all forms the Explanations and Definitions will appear. Here I feel the wording could be simplified and terms keep the same i.e. salespersons, associated persons etc., could just be stated as personnel. I think you could detail the difference in class of shares A, B, C a bit better. Also mention no load funds and index funds. Basically if you use the wording on your web site regarding mutual fund definitions that is very clear and add in the information on what the broker stands to gain by the sale.
I love the fact that you are making the information on incentives and compensation available to the investor at the time of sale This information is imperative for an investor to know up front as it directly effects their rate of return and in the past has been hidden or glossed over much to the investors detriment. Thank you for doing this.