December 27, 2002
I would like to submit the following comments about the proposed rule changes concerning the twice-a-year reports that the mutual fund companies are currently required to send to fund-holders.
I submit the following comments as an individual investor, who manages his own family’s investments, not as a “professional” money manager for hire, or as a hired spokesperson for any group or enterprise.
1. I don’t know exactly what the impetus behind the proposed rules is. I can only imagine that certain groups of individuals or entities expect to benefit from the proposed rule. These groups can be, for example, individuals who plan to do an end-run around the fund; fund-investor newsletter publishers; other competing fund managers; fund analysis companies that charge for their service, e.g., Morningstar, etc. etc.
2. I cannot imagine any individual investor benefiting from more frequent, but incomplete information. Under the proposed rules the funds would be required to give quarterly, but incomplete listing of all their holdings, which is useless to an investor. For example, if I have $10,000 invested in a stock, or bond, fund and the fund happens to be invested in, for instance, Enron, Worldcom, or Tyco etc., based upon complete information I can calculate how much money I have at risk. But under the proposed ruling the fund does not have to list all of its holdings but only the major ones. Under this system if any of the above listed companies do not constitute a major holding the fund does not have to list them. Hence, I am unable to calculate how much money I have at risk.
3. Furthermore, under the more frequent reports, by the time the fund prepares and publishes the report and delivers it to the customers, there is sufficient time lag to make any real changes to take the best advantage of the prevailing market conditions, or would be late enough to be of no use in making any changes to the fund portfolio.
4. I fail to understand how the fund companies will save money, as the claim, by publishing less information but more frequently.
Therefore, I urge the Commission to not approve the proposed ruling, which is detrimental to the individual investor, and at best of no value.
777 W. Calle Allegre Dr.
Pueblo, CO 81007