From: stocksnfund.com [stocksnfund@netscape.net]
Sent: Tuesday, March 11, 2003 4:37 PM
To: rule-comments@sec.gov
Subject: Comment to File No. S7-51-02


  Stocksnfund.com
  Pick A Stock, Find A Fund and More!

Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Comment to File No. S7-51-02; via e-mail

Dear Mr. Katz:

I appreciate the opportunity to comment on your proposed rule to require all 
mutual fund companies increase the disclosure frequency of their holdings. I 
occupy a unique new position within the investment community. I own and operate 
a new investment research tool web site. My business plan in July of 2002 was 
to provide an Internet web site for investors to research stocks held within 
mutual funds (Enron and WorldCom was my motivation). 5 months later on 
December 26, 2002 that goal became reality. It surfaced relatively quick that 
the concept and function of my web site met or exceed my business plan but feel 
short with regards to the accuracy of data provided to me from my monthly data 
feed service. 

2 Weeks ago I became aware of ic-258070/File No. S7-51-02. To say the least, I 
was pleasantly surprised. The overwhelming majority of “ comment “ letters 
submitted to you express my July 2002 position. 

I recognize and support many of the underlining issues such as Fidelity 
Investments statement “… appropriate balance is maintained between disclosure 
and confidentiality” (Summary of Contents, A. Quarterly Holdings Disclosure). I 
strongly believe that in today’s investment environment the average as well as 
professional investor needs accurate, timely and easy accessed to information. 

Comments from Charles Schwab & Co., Inc. (II. Summary Portfolio Schedule) “We 
believe use of a summary portfolio schedule in Fund Shareholder reports will 
result in more meaningful disclosure to Fund investors. Limiting disclosure to 
the top 50 holdings and any holdings in excess of one percent of the Fund's net 
assets will help investors focus on the most important Fund holdings …” is an 
outstanding statement and position. 

Capital Research and Management Company (II. Quarterly Filing of Portfolio Holdings) 
statement “ Our view of the quarterly filing requirement is simple: We believe the 
vast majority of fund shareholders have an interest in understanding their fund's 
investment results, and the major factors contributing to those results, on a regular 
basis, and quarterly reporting of major fund holdings is generally consistent with 
this notion” is also excellent.

I do struggle with the investment communities’ concept that “…60-day lag proposed 
for quarterly holdings disclosure should be adequate to inhibit front-running 
behavior while also providing reasonably current information to the public” 
(Fidelity Investments, Summary of Contents, A. Quarterly Holdings Disclosure). 
“… reasonably current information …” Is defined almost daily by the market. In a 
perfect world 60 days would be reasonable. We lost that on 9/11. I have to support 
Tom Dillion’s January 30, 2003 comments “ …I wish you would force them to report 
monthly”. 

I anxiously await the adoption of this proposal,

J. Wayne Stephenson
Stocksnfund.com
jws@stocksnfund.com
540-885-9900