May 13, 2008
While there is much to be commended in these rule changes, some are onerous and from an investor viewpoint worse than doing nothing. Specifically, the requirement to mail what will be a very large and Byzantine ADV Part 2 every year, at an estimated cost of over 250 hours of our time as advisers every year, to send a document that our clients won't read. Worse, the single most common spontaneous complaint that I get from my clients is the extreme volume of incomprehensible information they receive by mail now. Most wish they could stop receiving it. It adds enormous stress and loss of time, as they sort through mountains of mail to find the 5% that matter to them. Your surveys of customers have also confirmed this. I suggest a disclosure that those who are interested can go download the ADV from your website. the disclosure could be sent by e-mail or snail mail.
A piece of information that would be very helpful. and I didn't find (forgive me is is there and I missed it--160 plus pages is a lot of information for those of us with work to get to): have the big wire house brokers disclose the hidden extra fees associated with requiring that their customers use their trading desk, vs.. best price execution.
Russ Kyncl, CLU, ChFC
Strategic Exit LLC