Subject: File No. S7-12-10
From: Edward K, Watkins
Affiliation: chemist, looking for a job

June 23, 2010

(comment resubmitted, now with .pdf file)

Dear Chairman Schapiro --

Target-date funds are a joke. I perform technical analysis each week on stocks and mutual funds and have stopped examining target-date funds. Here is why:

If you look at target funds with a wide range of target retirement dates from a given financial firm (Schwab, JPMorgan, or American Century, etc.) and plot the 5-, 15-, and 40-week moving averages of these funds, these plots basically superimpose upon each other, provided that the dollar values on the Y-axis are ignored. This superimposition is a clear indication that the funds from a given financial house with widely different target retirement time frames (1 year to 30+ years) all fundamentally invest the same. The evidence supports my conclusion that these companies do not tailor these investment vehicles to the needs of each retirement tranche. Target-date funds are a sham in their current form and mislead their customers.

Copyright material redacted. Author attaches charts from for ARFIX, ARWIX, ARYIX dated 6/22/2010