Date:    06/30/2000  11:29 AM

Subject: S7-09-00:   33-78.09.htm

Regarding the ruling on After-Tax Performance Disclosure, I encourage you to 
also consider requiring disclosure of the imbedded capital gain in a fund as 
well as the historic distributions in absolute terms and or as a percentage of 
the overall imbedded gain.  
     
As an equity product manager I receive questions on this topic quite a bit, 
especially with the increased media coverage on taxes related to mutual fund 
returns.
     
Regards.
Maryann Cunningham
Equity Product Manager
Mitchell Hutchins