[ by Melanie Gretchen ] SIFMA's Private Client Legal Committee offered some suggestions for the SEC in a comment letter - a response to the SEC's study regarding financial literacy among investors, Release No. 34-6614; File No. 4-645, as per the Dodd-Frank Act. Prepared by Kevin Carroll, SIFMA Managing Director and Associate General Counsel, the Comment Letter urged the SEC to recognize that more disclosure is not better disclosure.  SIFMA recommended that the SEC study focus on several key aspects of financial disclosure that are critical to whether such disclosure is effective. In particular, SIFMA said the study should consider the ways investors use and access information from their service providers, particularly in light of technological advances that should be harnessed to improve delivery of information to investors.  These thoughts are expressed more fully, below. Specific Factors Relevant to Public Investors. In his Comment Letter, Mr. Carroll identifies these six factors as critical to any study that seeks the best ways to communicate financial information to individual investors.  They are:

1. Layered Disclosures.
2. Web-Based and Electronic Disclosures.
3. Incorporation by Reference .
4. Timing of Disclosures.
5. New Disclosures or Consents for Existing Customers
6. Clear Standards and Guidelines for Disclosure

SIFMA concludes with its belief that the SEC, "in conducting the study, should focus on each of the topics described above.  Doing so would provide the SEC with valuable information about the types of information, level of detail, and methods of delivery of disclosure that would effectively communicate critical information about financial services and products to different types of investors." "The question of how to communicate effectively to investors is of supreme importance and goes to the heart of the SEC’s investor protection mission. We believe that investors should have ready access to all levels of information about their financial services providers and products. In our experience, “less is more” at key decision points for investors. Thus, it is critical to determine what information should be presented in what form at these key decisions points. We stand ready to assist in this inquiry." To access the Comment Letter, go to:  [SIFMA, 3/23/12].