Comments on Proposed Rules Regarding Certification of Management Investment Company Shareholder Reports and Designation of Certified Shareholder Reports As Exchange Act Periodic Reporting Forms:

Table of Responses

Commenter Form N-CSR Form N-CS
and Form N-SAR
designated as
Exchange Act Reports		 Whether UITs
Should Provide
Certification		 Disclosure Control
and Procedures		 Compliance Date PRA Cost/Benefit
Analysis		 IRFA
1. SBA N/C N/C N/C N/C N/C N/C N/C Would like RFA to be more specific regarding alternative considered and need for new rules and forms
2. Equitable Certification should apply solely to financial information Certification should only apply to Form N-CSR N/C N/C N/C N/C N/C N/C
3. American
    Century		 Certification should be annual and should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with no certification requirement N/C Opposed to extending definition to all Securities Act, Exchange Act and '40 Act filings If release adopted as currently proposed funds would need 6 months from publication in Federal Register to comply. If adopted as requested, 90 days. N/C N/C N/C
4. ICI 2 N/C Form N-SAR should be '40 Act only form with no certification requirement N/C N/C N/C N/C N/C N/C
5. AIG, et al. N/C Form N-SAR should be '40 Act only form with no certification requirement No certification requirement N/C N/C N/C N/C N/C
6. New York
    City Bar		 Certification should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with no certification requirement No certification requirement Opposed to extending definition to all Securities Act and '40 Act filings (except N-CSR) N/C Seriously underestimated increase of 5 burden hours due to certification requirement, therefore aggregate burden hours is also incorrect. N/C N/C
7. T. Rowe
    Price		 Certification should apply solely to financial statements and financial information Form N-SAR should not have certification requirement N/C Opposed to extending definition to all Securities Act, Exchange Act and '40 Act filings Allow 90 days from date of publication in Federal Register N/C N/C N/C
8. Vanguard Certification should apply solely to financial data Form N-SAR should not have certification requirement N/C Opposed to extending definition to all Securities Act, Exchange Act and '40 Act filings N/C N/C N/C N/C
9. Corsell Certification should not apply to MD&A and President's letter Form N-SAR should not have certification requirement N/C Certification of disclosure controls and procedures should not be required. If required, eliminate timing requirement. Allow sufficient time N/C Review with more consideration to indirect costs and small fund groups N/C
10. Harvard
    Law School
    Professors		 Certification should apply solely to financial statements and financial information N/C N/C N/C N/C N/C N/C N/C
11. ICI Certification should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with no certification requirement No certification requirement Opposed to extending definition to all Securities Act and '40 Act filings Allow 90 days from date of publication in Federal Register, longer if disclosure controls extends to '33 and '40 Act filings N/C N/C N/C
12. AIM Certification should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with no certification requirement N/C Opposed to extending definition to all Securities Act and '40 Act filings. Concept of disclosure controls and procedures is not clear. Allow 90 days from adoption of rules N/C N/C N/C
13. CDC

Certification should apply solely to financial statements and financial information Form N-SAR should not have certification requirement N/C Opposed to extending definition to all Securities Act and '40 Act filings Allow 90 days from date of publication in Federal Register Reconsideration of burden of final rules is necessary. N/C N/C
14. Dechert Certification should be annual and should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with no certification requirement N/C Should be limited to Exchange Act filings. Provide clarification of concept of disclosure controls and procedures. Allow for only one annual review. N/C N/C N/C N/C
15. Federated Certification should be annual and should apply solely to financial statements Form N-SAR should be '40 Act only form with no certification requirement N/C Opposed to extending definition to all Securities Act and '40 Act filings. N/C N/C N/C N/C
16. Fidelity Certification should apply solely to financial statements Form N-SAR should be '40 Act only form with no certification requirement N/C Opposed to extending definition to all Securities Act, Exchange Act and '40 Act filings N/C N/C N/C N/C
17. ABA Certification should apply solely to financial statements and financial information Form N-SAR should be '40 Act only form with respect to management investment companies with no certification requirement. With respect to UITs and SBICs Form N-SAR should be an Exchange Act and '40 Act form and certification should not be required. No certification requirement Opposed to extending definition to all Securities Act and '40 Act filings. Allow 60 to 90 days from date of publication in Federal Register. Adopt transition provisions for N-CSR that are similar to those adopted for N-SAR--Evaluation and certification of disclosure controls and procedures should apply to reports on N-CSR filed for periods ending after compliance date for N-CSR. N/C N/C N/C
18. Corsell 2 N/C Form N-SAR should not have certification requirement N/C N/C N/C N/C N/C N/C
19. Mann Certification should apply solely to financial statements Form N-SAR should be '40 Act only form with no certification requirement N/C N/C N/C N/C N/C N/C

 

http://www.sec.gov/rules/extra/s73302xcsumm.htm
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Modified: 12/10/2002