November 29, 2007
I generally support the proposal. However, it seems to me that you need to tighten up the drafting on proposed rule 498(b)(2)(ii). The proposed rule says to provide in the table updated quarterly performance information. Dont you really mean for the summary prospectus to have the most recent quarterly performance information required to be stated in a footnote to the bar chart (as required by the second to last sentence of (newly renumbered) N-1A Item 4(b)(2)(ii)) updated quarterly (and make it required for funds that have fiscal year ends that end on 12/31)?
I note that your hypothetical summary prospectus doesnt have updated performance information in the table, but rather includes quarterly information for the quarter ended 9/30/07 below the bar chart, so it would seem that your hypothetical doesnt match your drafting.
I appreciate the opportunity to comment.