From: Mike Giles [mike.giles@computershare.com]
Sent: Friday, December 13, 2002 3:48 PM
To: rule-comments@sec.gov
Subject: Mutual Fund quarterly disclosure proposed rule (s7-51-02)

It makes perfect sense to require the mutual funds to disclose their 
holdings quarterly.  They already report it on the 13F, so it should 
not cause any additional work for them.
 
My recommendation is that they report columns similar to the 13F.  
Instead of only putting in the security name, we need them to put in 
the cusip as well.  
 
Thier quarterly holdings report should list:  Name, Cusip, Shares, Value
 
Thanks,
 
Mike Giles
Director of Operations
Computershare Analytics
301-881-2252 ext 226
Mike.Giles@Computershare.com