Subject: Comment on Suggested Rule 17j-1 Author: Jeff Schwarz Date: 12/11/98 12:34 AM Instead of having absolute disclosures, may I suggest having managers disclose their holdings based on percentages. Instead of saying they had a fixed number of dollars in a fund, they would instead be state what percentage of their savings were in their fund, or other relevant information. Let's say your fund was managed by someone worth a few hundred million dollars. What good does it do to know he or she has $100,000 invested in the fund? This is a small percentage of his or her net worth. On the other hand, if the manager of a fund told us that 90% of their savings was in the fund, well, now we really know whether they are committed to the fund's performance. I tried this theory out with a fund manager. I e-mailed him and discovered that he had about 2/3rds of his net worth (I forget if we included his home in the calculation) in the fund he managed. He also disclosed that he had no other significant equity holdings. Now I know exactly how committed he is to getting the best performance out of the fund - much more than you would ever find out if you learned that he had $50,000 in the fund. And I did it without invading his privacy at all. Likewise, we could be told that he has added 30% of his paycheck to the fund, rather than that he added $1,000 - 30% is a lot of money, $1,000 is a lot to some people, not to others, so who knows if that information is useful. We could be told that the manager's additions increased his or her holding by 50% - pretty significant - without violating their privacy I hope that you will consider this alternative "relative" disclosure (relative to the manager's entire worth) rather than the current "absolute" disclosure. It will provide us with more valuable information without continuing this country's march to invade all of our privacy. Thank you for considering my opinion. Jeff