E-Mail

February 10, 1997


Matland Money Management (801-39808) provides continuous
supervision of approximately $11,000,000 of investments for 15 clients in 7 states (registered in 4). The 
undersigned is the sole employee, working from the firm's sole place of business south of Boston in 
Sharon, MA.
As proposed, Instruction 7(d) to Form ADV-T would require that the
value of a securities portfolio be determined as of a date no more than ten business days before the filing 
of Form ADV-T.
My clients use multiple custodians. First, I receive regular
monthly paper statements from only two of these custodians, Schwab and Vanguard, through their 
investment adviser divisions. Second, I receive paper statements only either when there is activity or at 
quarter-end from those custodians where my clients' assets are too small to qualify for their investment 
adviser division, e.g. Fidelity, or custodians that don't have an investment adviser division, e.g., Harbor. 
Finally, I receive only quarterly paper statements on client assets held in 403(b), 457, 401(k), and 401(a) 
plans. Most such plans' recordkeepers only issue quarterly statements, e.g., TIAA-CREF, Copeland, State 
Street Bank. They generally do not issue duplicate statements, so the statements are first sent to my 
clients, who must then be reminded to send them on to me.
Accordingly, I suggest that an additional valuation date be
allowed: the valuation could be determined as of the most recent quarter-end if the adviser certifies that to 
its knowledge there has been no material change in assets in the securities portfolio since the quarter-end.
Respectfully submitted by
Kim Q. Matland

Matland Money Management   617.784.5220