BlankFrom: James H. Applegate, CFP [japplegate@aimria.com]
Sent: Friday, February 06, 2004 11:25 AM
To: rule-comments@sec.gov
Subject: Comment on File No. S7-26-03

Jonathan G. Katz, Secretary

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549-0609

 

RE:  File No. S7-26-03

 

Dear Mr. Katz:



I am writing to voice my support for the above-referenced proposal regarding market 
timing disclosures and specificity.  

 

As a registered investment advisor, I provide asset allocation and active risk management 
services for my clients using mutual funds.  I invest on an intermediate to long term 
basis and have never been restricted from using a fund due to a violation of the fund 
company's policies on frequent trading.  However, I know of other advisors who have been 
unfairly restricted from using funds even though they have fully complied with all of the 
fund company's advertised policies.  

 

I have long believed that the language fund companies use in their prospectuses regarding 
frequent trading and market timing is too vague and arbitrary.  It is time these 
companies adopt very specific language and disclose it in their prospectuses.  Their 
company policies regarding frequent trading must be the same for professional advisors as 
well as individual investors.  

 

I look forward to this proposal becoming law.

 

 

Respectfully,

 

 

James H. Applegate, CFP®, AAMS® 

Applegate Investment Management, LLC