March 28, 2004
I support this disclosure rule, and feel it is proper for fund managers to disclose their salaries and compensation salary is only one part of the plan and can quicly be redirected into other forms. Therefore, the rule needs to look at compensation and not just salary.. The arguement against this based on the potential harm to the market is concocted. Investors have the ability to judge this information in light of all other fund performance and disclosure information, and to make rational decisions. Indeed, it is the only way they can make a truly informed choice. Denying investors this data raises the question of what the fund managers have to hide, and if they have nothing to hide, and their compensation is consistent with industry standards, then they should also favor this rule.
I also suggest that the SEC must take two additional steps. First, the SEC should now revise the fund compensation cap in the Investment Advisor Act and Investment Company Act downward - significantly. In todays, extremely high dolar value funds the amount of money funds can legally charge is completely out of line with the service they perform. As funds have grown from a few million dollars to several billion dollars in assets, the increase in fees is not justified. The funds have very little incremental expense as fund assets frow, and as funds typically charge what they can - the highest percentage allowed by law, they have a hoard of cash to use, resulting in decresed returns for investors, and excessive salaries and perks for fund managers and firms. It has reached the point of being disgusting. This profession adds little true value to the eceonomy, and hence should not be provided the excessive rewards it now enjoys.
Second, fund managers should not be able to invest their personal money in their own funds. This is a direct conflict of interest.
Thank you for this opportunity to comment on this new rule. I strongly urge the Commission to take additional steps to curb the excessive compensation of fund manaagers and firms.