February 5, 2004
Jonathan G. Katz, Secretary
Re: File No. S7-26-03
Dear Mr. Katz:
I am grateful for the opportunity to provide my comments with respect to the proposal by the Securities and Exchange Commission Amendments on Disclosure Regarding Market Timing (S7-26-03).
I am a registered investment advisor for a small firm. Our clients are mostly middle class working or retired individuals and rely on our expertise, especially in decreasing their risk in the investment process, to assist them in achieving their investment and retirement goals. Just as most average investors and small advisory firms do, my firm follows the "market timing" policies and rules in place as they apply to each fund. The problem currently is that the mutual funds' policies in this area are ambiguous and subject to whatever interpretation they deem appropriate for each separate circumstance. Advisors and investors must be given clear and specific fund policies in order to manage their investments successfully. Therefore I am in full support the proposal requiring mutual funds to fully disclose their policies regarding what they call "market timing."
I certainly welcome any Securities and Exchange Commission's attempts at achieving greater transparency, accountability and governance in the mutual fund industry. Thank you for permitting me to submit my opinions for review.
Very truly yours,