Subject: File No. S7-35-04
From: James G Squyres
Affiliation: President, Buyside Research

November 19, 2005

Mutual fund companies submit list of holdings in funds each quarter to the SEC. By attaching CUSIPs to each of the securities in a portfolio, data vendors and investors can then identify and process this information with computers.

Mutual fund companies universally use CUSIPs for interactive communication with brokers, custodians and others. To attach these identifying tags to SEC filings would require little extra effort.