March 21, 2004
I think its probably good for investors to have such information. But I have the following comments:
1. The information reminds me of the Privacy Information that I see from financial institutions or health care providers. It is required by legislation, but I know I do not read much of it and doubt if many other people do either. It is an increased cost that we consumers pay.
2. Similarly, I would expect that the Funds costs would go up by some amount so as to provide the information: developing the data, cost of paper and printing, personnel to develop and maintain data, etc.
3. Would the Fund get the Industry Norms information from the SEC? From their own data? Elsewhere? Would the Fund have to buy it, thereby increasing its costs to investors? How could the investor have confidence in the Norms data?
4. I think a better way would be to have the information in the Prospectus, current as of a date on the cover, and leave it up to the investor to read it if desired. If the data changes after Prospectus printing, it could be on an internet web site, or available at an automated 800 phone number. All of these would increase costs, however.
...end of comments...