Jonathan G. Katz, Secretary
Regarding: File No. S7-27-03
Dear Mr. Katz:
The "hard close" proposal is not going to fix the problem; instead, it will open up the system to other types of abuse. This is going to create a situation where millions of investment instructions from financial intermediaries are held in limbo because they could not get processed before 4:00 pm. The same mutual fund insiders that cheated the system before will get access to that information and buy or sell ahead of the funds knowing that when these orders made good the mutual funds will move up or down accordingly. All you will have done is create a new type of market timing advantage for those who don't play by the rules.
I agree that we need to address the mutual fund scandal. But for individual investors like me these funds represent my life savings. I need the system to be protected and I know that is what you are trying to do. But this hard close concept is not the way to do it. I strongly urge you to adopt the alternative proposal you outlined in your recommendation. It gets you to the same place and it doesn't set up what I believe is a system that will be mis-used just as badly as the current system.
Leni M. Lambert