The following comment on Letter Type F,
Letter Type F:
Mr. Jonathan G. Katz
Re: Proposed Amendments to Rules Governing Pricing of Mutual Fund Shares, File No. S7-27-03 -
Dear Mr. Katz:
As a sponsor of retirement plans for public sector employees, I believe that regulations proposed by the federal Securities and Exchange Commission would place our employees/investors at a severe disadvantage.
We believe that the regulations proposed by the SEC will not correct the serious problems the commission is attempting to address. Instead, the solutions outlined would reduce the fund options and increase the costs for investors in these plans.
We believe that the proposed change would have the following adverse impacts on the investors in our plan:
As an alternative, we endorse the proposal that would require our administrator to mark the transactions at the time received in a manner that would prevent manipulation of the trades. In addition, we advocate very tight third-party oversight of the administrator to prevent abuses.
Thank you for your attention to this matter.