While requiring disclosure of additional information regarding complex financial products seems good in principle, it seems quite possible that this will be yet another textual agreement that almost nobody reads and most people click through. Figuring out who needs the information provided and how to present it in a way that they will understand it seems important.
However, requiring testing to trade in financial products such as target-retirement-date funds seems absurd. What this will most likely do is enrich the rich (who can learn how to pass the test) while negatively impacting the less well-off. Before making it harder for people to invest in their retirement, you should run a pilot study that evaluates the impact.
Jason Gross Comment On Regulatory Notice 22-08
While requiring disclosure of additional information regarding complex financial products seems good in principle, it seems quite possible that this will be yet another textual agreement that almost nobody reads and most people click through. Figuring out who needs the information provided and how to present it in a way that they will understand it seems important.
However, requiring testing to trade in financial products such as target-retirement-date funds seems absurd. What this will most likely do is enrich the rich (who can learn how to pass the test) while negatively impacting the less well-off. Before making it harder for people to invest in their retirement, you should run a pilot study that evaluates the impact.