Subject: File S7-10-97
Author:  "Werner Renberg" <werren@worldnet.att.net> at Internet 
Date:    6/20/97 6:14 PM
     
     
     As a journalist and author of books on mutual funds, I have the need
to study many fund prospectuses and shareholder reports, and have observed 
an unevenness in at least one important respect that, I believe, could be 
fairly easily corrected by means of revised requirements for these 
documents, beginning with Form N1-A.
     This is that 10-year tables of financial highlights appear not always
to indicate, with appropriate footnotes, changes in investment advisers and 
significant changes in sub-advisers, investment objectives, and investment 
policies.
     Such changes may sometimes be footnoted in the first year or two
following their occurrence but disappear subsequently, even though the 
years of their occurrences are still within the 10-year time frame.
     I believe that investors desserve to know--and should want to
know--whether records of 10 years (or fewer years, in the cases of newer 
funds) include changes in management and/or policy that should be taken 
into account when considering relative and absolute performance in the most 
recent period(s). They may have been significantly below the average for 
the 10 years as a whole, making it even less appropriate to extrapolate 
10-year averages into the future; they also could have been significantly 
better.
     The same comments about appropriate footnotes for 10-year periods
apply not only to all presentations of data in tabular form but also to the 
charts of 10 years' bar graphs that indicate volatility in returns (which 
would be a welcome addition to the literature of funds that have not 
offered them voluntarily).
     In this context, feeling the importance of having a comprehensive
picture of a fund's most recent 10 years, I disagree with the notion that 
appears to be expressed in the release that data or bars could start with 
the first year of an adviser's services in cases where advisers were 
changed during the 10 years.
     You also may wish to consider other candidates for footnotes, as
appropriate: changes in control of investment advisers and in portfolio 
managers, as well as major changes in expenses (such as the implementation 
of 12b-1 plans).
     Finally, I would hope that you would consider requiring that the
presentations of data and bars for periods of two or more years be uniform 
in starting or ending with the most recent year. I believe that uniformity 
is not required now; it should help many investors who own two or more 
funds and might be started occasionally by a prospectus or report from a 
fund complex whose presentations differ (going from left to right) from the 
majority.
     In respectfully submitting these thoughts for your consideration, I
wish to compliment you for the extensive effort that you have undertaken to 
help improve the usefulness of fund prospectuses.
                                                Werner Renberg