Subject: File No. S7-31-08
From: Gerrit j van der Zwan
Affiliation: Compliance Consultant

November 4, 2008

In the final Form SH the Total Number of Transactions Reported is requested.

In the instructions in another document on the SEC website ( it states that the total number of line items need to be reported here.

We request that you consider changing the form to better match the requested information. We'd expect to only provide the number of trades rather than holdings and trades here.

An older version of the Form SH had a better request. (
Form SH Information Table Entry Total