MEMORANDUM

        January 10, 2003
TO: Files
FROM: Daphne Tippens Chisolm
Counsel to Commissioner Goldschmid
RE: Release Nos. 33-8164; 34-47023; IC-25870; File No. S7-51-02

On January 3, 2003, Matthew Fink of the Investment Company Institute ("ICI") met with Commissioner Goldschmid. One of the topics of conversation concerned the Commission's proposal to require more frequent portfolio holdings disclosure by investment companies (see Shareholder Reports and Quarterly Portfolio Disclosure of Registered Management Investment Companies, Release No. IC-25870 (Dec. 18, 2002)). Mr. Fink expressed concerns that will be included in the ICI's comment letter on the proposal.