March 4, 2004
Honorable Ladies and Gentlemen,
I am very concerned about the items listed below from
proposed SEC Rules 15c2-2 and 15c2-3.
The items listed below and how the proposed SEC Rules 15c2-2 and 15c2-3 handles them are some of the key items of my concern.
The disclosure of sales load costs incurred at the time of purchase, and the amount of that load that would be paid to the broker/dealer
You will have to disclose asset-based sales charges and service fees paid out of fund assets in the year following the purchase assumes net assets remain unchanged, or based on a hypothetical 10,000 investment
Specify the maximum amount of any deferred sales load that would be associated with the purchase if the shares are sold within one year, along with a statement about how many years a deferred sales load may be in effect
Transactions may be revocable if it is proved client was not provided disclosure
Any revenue sharing arrangements must be made known
This rule proposal may be the first step toward eliminating or modifying the collection of 12b-1 fees, which is sufficient reason for you to respond to the SEC
The current Mutual Fund Disclosure Form will be expanded in length and nature.
The proposed SEC Rules 15c2-2 and 15c2-3 are over 100 pages long. This is entirely too much information to study and respond to in 60 days. I respectfully request that you extend this period to a minimum of 120 days.
Sincerely,
Lloyd Lowe Sr.