May 28, 1999
     
     
Mr. Jonathon G. Katz, Secretary
Securities and Exchange Commission
450 5th Street, NW
Washington, DC
20549-0609
     
Dear Mr. Katz:
     
Re:  File No. S7-10-99
     
     
Global Strategy Financial Inc. ("Global") is a manager member of the 
Investment Funds Institute of Canada ("IFIC") and currently manages 23 
mutual funds with aggregate assets of approximately C$6.7 billion.  We 
are writing to indicate that we are particularly pleased that the 
Securities and Exchange Commission (the "SEC") has published proposed 
rules to address a highly significant issue for U.S. participants in 
Canadian tax deferred retirement accounts ("retirement accounts"). Over 
the last several years, a significant number of such investors in the 
funds we manage have not been able to implement certain investment 
decisions pertaining to their retirement accounts.  Given that the 
proposed rules, if implemented, would be of significant benefit to these 
U.S. residents and visitors, we believe their implementation, in the 
near term, is highly desirable.
     
You have specifically sought comment on a number of issues and we wish 
to provide our views on several of these issues.  More specifically, 
you have sought comment as to whether Canadian mutual funds commonly 
use joint prospectuses or other joint information materials to offer 
and sell securities of more than one fund.  In the case of Global 
Strategy, we have two prospectuses that offer two fund families with 18 
and 5 funds, respectively, offering securities under each prospectus. 
All reporting information required by Canadian law to be provided to 
unitholders with respect to a fund family (and otherwise regularly 
provided to investors) consolidates the information for all funds in a 
single document and  sales communications frequently pertain to more 
than one mutual fund.   It is therefore a practical impossibility that 
no information  with respect to a fund be provided to a person in the 
U.S. who does not hold units in such fund.  To proscribe the provision 
of information under such circumstances might well negate the intended 
effect of the proposed rules.
     
You have also sought comment as to whether it is necessary that all 
written offering materials (including sales communications) disclose 
that the securities offered (or in the case of sales communications, 
where there is an inducement to purchase the securities) are not 
registered with the SEC.  In our view, it would be appropriate to limit 
such disclosure only to the prospectus as this document must be 
provided to each purchaser before a trade can be completed.  Moreover, 
given that the overwhelming majority of
     
     
investors in our funds are Canadian residents, the cautionary language 
suggested would not be meaningful or of any utility. 
     
We wish to thank you for the opportunity to comment on the proposed 
rules.
     
Yours truly,
     
     
Arnold Hochman
Executive Director, Finance