AMG Data Services
Via Email: email@example.com
February 14, 2003
Robert L. Adler
Re: File No. S7-51-02 Proposed Rule: Shareholder Reports and Quarterly Portfolio Disclosure of Registered Management Investment Companies
Members and Staff of the Commission:
AMG Data Services1 will be directly influenced by passage of S7-51-02 and I appreciate this opportunity to comment. I have interacted with the Commission in various brokerage capacities since 19722 as well as on issues facilitating market transparency3. AMG collects portfolio filings from EDGAR and information from Registered Management Investment Companies4 to calculate5 investor demand. In 2002, I demonstrated to Commission staff the capabilities of the AMG Holdings and Money Flow Database of these companies6. AMG distributes investor demand information7 weekly8 to an array of customers9
Investment manager13F quarterly portfolio filings disclose activity in domestic equities10. Passage of this rule will disclose quarterly activity in non-domestic equities as well as fixed-income securities. AMG maintains a relational database of security holdings in 13F and open-end company semiannual filings required on EDGAR11. Reports describe historical activity in an individual security,12 a ranking of fund activity in that security and the nature of that activity13, and a positioning of activity in that security relative to other portfolios holding that security and others with a common investment style.14 Debt securities15 and non-domestic equities16---sectors not disclosed in the 13F dataset--- can also be queried. Similar report types can be generated from the 13F dataset17. Each security is identified and assigned industry, country, and currency codes, and can be related to other securities to build semiannual open-end and quarterly investment management portfolio datasets managed passively18, actively, or created ad hoc19.
AMG Data Services will increase its processing frequency for quarterly open-end company portfolio filings on EDGAR.
To facilitate transparency, enterprise ad hoc database access---with redistribution rights available---is being offered to AMG customers, mutual fund companies, managers, and advisors- either directly or through the industry trade association, and to government organizations.
Increased transparency from quarterly disclosure of portfolio activity will empower investors to make better informed decisions. Providing responsible oversight of this kind will go far to protect investors and maintain the integrity of the securities markets.
cc: The Honorable Harvey L. Pitt