Subject: File No. S7-11-08
From: Wahlberg G Olof, Ph.D
Affiliation: Universitetslektor (Associate Professor), Mittuniversitetet (Mid Sweden University)

January 4, 2009

I wish to endorse the initiative of the Commission in 'pushing' the Mutual Fund industry into disclosing, by way of tags, Risk and Return information.

Some comments on the proposed final rule criticize the lack of uniformity of the presentation of the data due to the Commission's concurrent consideration of the formatting of the said data in 'hard copy' format.

I do not believe that this alleged hindrance to comparability of risk and returns, due to evolving format design, is a valid criticism. There is evidence to the contrary. Prescribed formats are often ignored by readers over time. This could be an argument for not being so 'prescriptive' in the format...perhaps resulting in great reader attention to the RR data

Several commentators have rightly referred to the SEC viewer and transposition problems. I am sure you are addressing this.

I do not believe that the MF industry deserves any more time to implement this proposed final rule. The voluntary phase was iniatated as long ago as February 6th 2007. From start to implementation a period of circa 33 months will have elapsed

The time for implementation is NOW. The impact on global financial markets is significant.


Dr Olof Wahlberg
Universitetslektor (Associate Professor),
Mittuniversitetet (Mid Sweden University)