From: Rich.C.Krahulec@supervalu.com
Sent: Friday, January 02, 2004 4:11 PM
To: rule-comments@sec.gov
Subject: S7-27-03:

SUPERVALU INC. respectfully submits this comment in response to proposed regulation 
"Amendments to Rules Governing Pricing of Mutual Fund Shares," File No. S7-27-03, 
published on December 11, 2003. 

SUPERVALU has approximately 20,000 participants with account balances in its 401(k). 
As a plan sponsor, SUPERVALU is very concerned that proposed late-day trading 
regulations would place our workers and retirees at an unfair disadvantage relative 
to other investors, effectively subjecting them to different trading rules and, 
ultimately, different trading prices than other investors. Although we strongly 
endorse measures to strengthen the mutual funds and repair the damaged image of the 
industry, we are concerned about potential unintended consequences of the proposed 
regulations. 

The proposed regulations would require that all entities submit mutual fund trades 
to the mutual fund, or their authorized agent, by 4:00 p.m. Eastern time. Because 
of the extensive processing and calculations required, the proposed rules would 
require an earlier cutoff time for 401(k) investors, requiring them to make their 
investment decisions many hours earlier than 4:00 p.m. This is an unfair restriction 
to place on plan participants, and it has the potential to severely impact the 
retirement distributions for investors. We know that our employee 401(k) participants 
will care deeply about this proposed change and will react negatively to having 
lesser trading rights than other investors. Accordingly SUPERVALU supports a 
combination of the alternatives outlined in the proposed rule: 

1.        Electronic time-stamping of orders in a manner that cannot be 
altered or discarded once the order is placed. 
2.        Annual certification that the 401(k) recordkeeper has policies 
and procedures in place to prevent late trades, and that no late trades 
were processed. 
3.        Annual audit of the 401(k) recordkeeper's controls conducted by 
an independent public accountant who would submit his report to each fund's 
chief compliance officer. 

We believe that our employees and other 401(k) participants are small investors whose 
best access to the stock markets is through their 401(k) plan.  They have been shown to 
be methodical long-term investors, whose actions have helped stabilize and support the 
stock markets.  They do not deserve to be disadvantaged in reaction to other's actions.  
In closing, we submit this comment in the best interest of our retirement savings plan 
participants. 

We urge the SEC to give serious consideration to allowing adequate alternatives to the 
hard 4:00 p.m. cutoff. We support the alternatives outlined in the proposed regulations, 
and we are confident that they will fulfill the SEC's objective of drastically limiting 
the opportunity for illegal late-day trading while still preserving the right of 401(k) 
participants to place trades up until the market close and get that same day's price. 



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Rich Krahulec
Manager, Retirement & Savings Plans
952-828-4404 
952-828-4260 FAX
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