U.S. Securities & Exchange Commission
SEC Seal
Home | Previous Page
U.S. Securities and Exchange Commission

Summary of Comments
on Proposed Rules Regarding Certification of Management Investment Company Shareholder Reports and Designation of Certified Shareholder Reports as Exchange Act Periodic Reporting Forms

November 27, 2002


Prepared by Tara L. Royal and John M. Faust
Division of Investment Management

Webmaster Note:   Document also available in PDF format for ease of printing.

List of Commenters

Industry Comments

Funds/Investment Advisers/Financial Advisers

1. American Century Investment Management, Inc. American Century
2. CDC IXIS Asset Management Advisers, L.P. CDC
3. AIM Advisors, Inc. AIM
4. Federated Investors, Inc. Federated
5. The Vanguard Group Vanguard
6. Equitable Life Assurance Society of the United States Equitable
7. Fidelity Investments Fidelity
8. T. Rowe Price T. Rowe Price
9. Marvin Mann (on behalf of independent trustees of domestic mutual funds advised by Fidelity Management & Research Co.) Mann
10. AIG American General, Allmerica Financial Corporation, Great-West Life & Annuity Insurance Company, Hartford Life Insurance Company, Jackson National Life Insurance Company, and Jefferson-Pilot Corporation AIG, et al.

Professional and Trade Associations

1. Investment Company Institute ICI
2. Investment Company Institute
(Goldschmid Meeting)

Law Firms/Law Professors/Attorneys/Bar Associations

1. Professors Lucian Bebchuk, Jeffrey Gordon, Robert Pozen, and Reiner Kraakman (Harvard Law School) Harvard Law School Professors
2. Laura Anne Corsell Corsell
3. The Association of the Bar of the City of New York New York City Bar
4. Dechert Dechert
5. Laura Anne Corsell (follow-up letter) Corsell 2
6. American Bar Association, Section of Business Law ABA


1. Michael R. See (SBA) SBA

Summary of Comments by Commenter



Modified: 12/10/2002