March 6, 2004
I received a written request dated 2/12/04 from Susan Feris Wydenko to comment on this matter.
While I support the SECs efforts to enforce our securities laws and level the playing field for all investors, the proposed regulation is serious overkill. Its only tangible effect, I believe, would be to increase the compliance cost for all funds, a cost which would only be passed down to investors through lower overall performance after expenses. A second tangible effect would be to kill more trees and add to landfill burdens.
Rather than requiring more paperwork for each transaction, which I believe few investors would bother to read anyway, a better approach would be to require the funds to include more definitive statements regarding their trading policies and other matters addressed in S7-06-04 in the prospectus, and for the SEC to then ensure that they adhered to those policies.