January 14, 2005
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
Dear Mr. Katz:
I am writing to you today on behalf of the College Savings Foundation ("CSF"). CSF is a 501(c)(6) organization dedicated to the advancement of 529 college savings programs. CSF's mission is to help American families achieve their education savings goals by working with public policy makers, media representatives and financial services industry executives in support of education savings programs. CSF's members include many of the country's leading financial services firms, and collectively manage approximately $15 billion in savings-type qualified tuition programs, representing about one-third of the dollars in such programs. CSF also includes associate members that are governmental and non-profit agencies and individuals who support CSF and its mission.
CSF serves the education savings industry as a central repository of information and an expert resource for its members and for representatives of state and federal government, institutions of higher education and other related organizations and associations. The primary focus of CSF is building public awareness of and providing public policy support for 529 plans - an increasingly vital college-savings vehicle.
This letter is in response to proposed rule amendments submitted by the MSRB to MSRB Rule G-21. CSF is generally in favor of the proposed amendments contained in the Notice, which would generally bring advertising rules for 529 college savings plans in line with the requirements of SEC Rule 482. Our one comment is a request for adequate time to implement necessary systems changes to comply with the proposals. Although CSF members generally comply with the proposals in the context of administering mutual fund businesses, it may take some time to implement the systems changes needed to do the same with respect to 529 plans. Although we anticipate that most members will be able to comply very quickly, we request that there be a 180 day transition period from the effective date of the proposals until the date of required compliance.
Please do not hesitate to call me at 817-474-8298 or send an e-mail to me at firstname.lastname@example.org if you believe we can be of further help.
David J. Pearlman