Subject: proposed new ADV disclosure requirements

Date:    05/28/2000 9:41 PM
     
     
I understand that you are proposing changing the ADV disclosure to existing 
clients to annual mailing of latest ADV-II instead of just annual offer of 
it.   From my experience, clients and indeed everybody, already feel 
overwhelmed by and prefer less rather than more paperwork.  Thus, to receive 
a document that they already previously received year after year seems 
overkill if nothing has changed in it.
     
As I believe you're also proposing mailing to them a new copy of the ADV any 
time it is amended, that should amply address making sure they are kept 
informed of any changes which makes the annual mailing even more redundant. 
Thus, I would strongly recommend removing the annual requirement and instead 
requiring mailing any amendments or notification of all changes in any 
amendments filed (just as we now have the option of distributing an 
alternative document to the ADV-II as long as all the information required is 
included).   That way if only 1 page or section of the ADV-II has changed, 
the clients don't get overwhelmed with more pages than they need to pay 
attention to.  This is particularly important as the more pages they have to 
deal with, the greater their tendency to discard it.   Thus, by limiting the 
mailings to them to only amended pages or information, you're significantly 
increasing the likelihood that they will pay attention to and thus become 
aware of all changes.  Otherwise, it will most likely get tossed in the 
garbage just as most already toss the current ADV because it's more 
information than they want to sift through + usually already covered in the 
contract and other communications as to all relevant aspects.
     
Thus, much as you came up with a simplified and shorter prospectus to 
increase the likelihood of people reading and understanding the most 
important and relevant information, my experience shows me it's very 
important to come up with a shorter and more concise way to make sure clients 
will read and become aware of any changes.
     
I also understand that you're planning to make at least part of the ADVs 
available for anybody to look up on the Internet.   As an adviser who's 
limited by health constraints as to number of clients I can take on, I 
actually prefer not to be on any lists where people can call me as that 
unnecessarily increases the number of calls I have to deal with.   Thus, I'm 
hoping that if you are going to list all our information and make it 
available to the general public, there'd be a way to opt out or mark if we're 
not taking new clients or don't want to be considered by new prospects.
     
If helpful, I can be reached at 650-321-3012 and I am a CA state-registered 
investment adviser but we are affected by the rules you pass.
     
Thanks for your good work,
     
Yasmin Mansoor