AMG Data Services

Via Email:

February 14, 2003

Robert L. Adler
AMG Data Services

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.


Robert L. Adler
AMG Data Services

cc: The Honorable Harvey L. Pitt
The Honorable Paul S. Atkins
The Honorable Roel C. Campos
The Honorable Cynthia A. Glassman
The Honorable Harvey J. Goldschmid
Paul F. Roye, Director
Steven M. Cutler, Director
Alan L. Beller, Director
Annette L. Nazareth, Director

1 AMG Data Services is a wholly owned (Robert L. Adler) California based Subchapter S corporation that operates independently.
2 Central Registration Depository #1645
3 In 1985 the Commission took a staff no-action position for an electronic execution system Re: Robert L. Adler & Co., Inc. (Municipal Bond Trading System, 8/7/85). In 1990 I commented on related issues of market transparency, in a letter ("") to the Commission.
4 16973 ( Equity, Taxable Bond, Money Market, and Municipal Bond open-end share classes as of 2/12/03.
5 Price, asset, and distribution information are components in the calculation ( of marginal (net-cash) investor flows for each open-end share-class.
6AMG Database Summary ( and excerpts from letter ( to Commission staff 1/30/02
7Equity MoneyFlow Aggregate Report (
8 The MoneyFlow database ranges from 1/8/92.
9 AMG Best Customers:

      Bank of America Securities
      BBV Latinvest Securities
      Bear Stearns & Co.
      Cantor Fitzgerald
      Capital Growth Management
      CIBC World Markets
      Credit Suisse First Boston
      Daiwa Securities
      Dresdner Kleinwort Wasserstein
      Fidelity Management & Research
      Goldman Sachs & Co.
      Joint Library-International Monetary Fund/World Bank
      J&W Seligman
      JP Morgan Chase
      Kingdon Capital
      Lehman Brothers
      Leuthold Group
      Lone Pine Capital
      Merrill Lynch
      Moore Capital Management
      Morgan Stanley
      Prudential Securities
      Salomon Smith Barney
      Thomas Weisel Partners
      Tiger Management
      Toronto Dominion
      UBS Warburg
      Vinik Asset Management
      Wachovia Securies
      Waddell & Reed

10 Except American Depository Receipt activity which is reported in 13F filings
11 All equity funds from the top 20 complexes; all International equity and debt funds; all funds greater than $500 million; all High Yield debt funds, and all 13F portfolio filings.
12 Liquidity Survey-AOL (
13 Liquidity Ranking Report-AOL (
14 Liquidity Index Rankings-S&P 100 (")
15 Liquidity Survey-Nextel 9.375% (; Liquidity Ranking Report-Nextel 9.375% (; Liquidity Index Rankings-High Yield Bond Holders (
16 Liquidity Survey-Nokia ("); Liquidity Ranking Report-Nokia (
17 13F Portfolio (")
18 Liquidity Index Rankings-S&P 100 (
19 Any combination of securities held in portfolios included in the database.