Subject: File No. S7-11-08
From: Ashley W Burrowes, PhD, FCA(NZ)
Affiliation: Professor of Accounting, Woodbury University

December 27, 2008

I commend the Commission for progressing the up to now voluntary disclosure of interactive data on Mutual Fund Risks Returns. The SEC is charged with protecting the public interest and this is according to the industry association (ICI)survey, one of the vital pieces of information that investors require.

I was disappointed at the small number of mutual funds that participated in the voluntary scheme. This reflects unfavorably on their concern for investor and the public interest.

I believe that many of the comments on the proposed final rule from the industry are admissions of member procrastination and reveal lethargy about providing information in interactive form that is useful to investors.

'De minimis' adherence to the initial voluntary program has now given rise to 'yelps' on timeliness for compliance. These comments are heard but not empathized with as initial compliance is not required until after Dec 31, 2009.

I urge the Commission to not extend the initial start date, as being suggested by several commentators.

At this time of financial market turmoil, when mutual funds are not performing satisfactorily, the need for interactive access to mutual fund risk and return data is heightened.