May 21, 2004
Ladies and Gentlemen:
Please require complete disclosure of compensation and potential conflicts of interest by all persons involved in managing a mutual funds and mutual fund company managers.
The mutual fund Managers and all higher level personnel and persons of interest should be willing to report all compensation and potential conflicts of interest to prospective or present fund participants. By all compensation, I include supplements such as services provided them by vendors such as brokerages and research firms, entertainment, compensation from other funds or professional relationships presented all in illuminating detail. By fund I include all funds specifically including bond funds. By mutual fund manager I specifically include all members of fund management committees or management teams responsible for making buy/sell/borrow/lend decisions.
It is hard to convince me that a fund manager who is nominally investing my funds for my benefit in a retail fund can also manage a hedge fund that might sell short or borrow money. In a similar vein, persons involved in managing or supervising more than one fund or financial vehicle with or without different fee structures, 12b1 fees, quid pro quo expenses, front end loads, rear end loads, etc. must encounter specific conflicts many times over a year.
The fund industry folks should have nothing to hide. We, the unwashed small investor, do not need any more Janus personal experience or Putnam or Strong or etc. examples. Honest disclosure of compensation, real or potential conflicts of interest and all fees all in one easy to find, read and understand public location is a reasonable request to be made by the public to the SEC and reasonable for the SEC to require of the financial fund/brokerage industry.
Thank you for the opportunity to comment on this proposed regulation.