From: Robert Hughes [rhughes@oppenheimerfunds.com]
Sent: Friday, October 11, 2002 11:24 AM
To: rule-comments@sec.gov
Subject: File No. S7-28-02

Dear Mr Katz:
 
Please excuse my late reply regarding Custody Issues (File No. S7-28-02).  
Due to the large increase in popularity of WRAP Accounts, I would recommend 
that a section be included to cover such accounts.  In particularly, the 
responsible around custody and billing requirements.  

Thank you,


Robert M. Hughes
Securities Compliance Adm. & Compliance Officer 
OppenheimerFunds, Inc.
6803 South Tucson Way
Englewood, Colorado 80112
303.768.5828
Fax: 303.768.2905
rhughes@oppenheimerfunds.com


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