Proposed Rule IC-25870From: J Turner [jturner@mapwizards.com]
Sent: Wednesday, January 22, 2003 9:40 AM
To: rule-comments@sec.gov
Subject: Proposed Rule IC-25870 (s7-51-02)

Sirs:


This letter is to provide comment on the proposed SEC rule requiring more 
complete shareholder reports and more frequent portfolio disclosure for 
mutual funds.  As an investor in mutual funds, as are most working Americans 
who participate in pension plans or college funding plans, I am very concerned 
about information available from these funds who aggressively advertise for 
my business.  It is difficult enough to judge how a fund manager will act 
in different market conditions based on the usually-unsupported advertising 
claims about their 'philosophy' or their performance.  It is all too easy 
for an investor to become overly weighted in popular equities, unknowingly, 
because many funds invest in the same stocks.  The current rules allow fund 
managers too much time between reporting periods, and they are adept at 
adjusting their holdings just before the reporting is required.  Going to 
quarterly reporting will  greatly help to eliminate these night-before 
shifts, and also provide investors with information they need to maintain 
diversification across mutual fund portfolios.  The funds will lobby furiously 
against these disclosures, and is is possible that you will not hear from many 
individual investors.  However, please stick to your proposals -- which actually 
could go quite a bit further -- and give this  additional assistance to investors 
by requiring more information on holdings, more often, from mutual funds.


John Turner
1210 Daviswood Drive
McLean, VA  22102




In Re:


http://www.sec.gov/rules/proposed/ic-25870.htm

Proposed Rule:
Shareholder Reports and Quarterly Portfolio Disclosure of Registered Management Investment Companies

SECURITIES AND EXCHANGE COMMISSION
17 CFR Parts 210, 239, 249, 270, and 2747
[Release Nos. 33-8164; 34-47023; IC-25870; File No. S7-51-02]
RIN 3235-AG64