February 1, 2004
Comments about Proposed Rule: "Disclosure Regarding Market Timing and Selective Disclosure of Portfolio Holdings."
These comments are about Market Timing.
I am a small investor in mutual funds. I generally invest for long term holding, in the hope that the value of the fund will increase appreciably by the time I decide to sell. I feel that there should be no restrictions (or only minimal restrictions) on the timing of my sale after purchase.
I do my best to investigate and consider funds that are likely to improve the value of my portfolio. I sometimes make mistakes in judgment and decide I need to sell a fund fairly soon after purchase. Sometimes I need money unexpectedly to pay medical bills or to make emergency repairs to my home. I sell the fund or funds that have least impact on my portfolio. Sometimes I need to sell a fund that I only recently purchased.
I would like to see no penalty imposed even if I sell a fund within a week or so of purchase. However, if any penalty is to be imposed, I feel the minimum holding time should be only 10 or 12 days. I am not an after-hours market timer. If there is a redemption penalty, it should be no more than 1% of the sale price.
I feel the minimum holding time and the redemption penalty (if any) should be conspicuously stated in the Prospectus for each mutual fund, not by reference to some other document that may not be readily available.
Thank you for your consideration of my comments.
Francis J. Batchelder