December 29, 2002

The Commission should consider the disclosure of brokerage commission costs and related soft dollar costs as part of its proposal to improve expense disclosure.

Currently, mutual fund expense ratios disclosed in the prospectus exclude brokerage commission costs. However, this information is available separately, by way of a supplement to the prospectus. This limited disclosure is inappropriate, especially when brokerage commissions can be used to pay for other products and services through soft dollar arrangements. This allows soft dollars to be used to avoid disclosure of expenses.

Additionally, as brokers move increasingly towards trading on an agency basis in NASDAQ stocks, disclosure of brokerage costs becomes more relevant.

Erich Riesenberg