Subject: File No. 265-28
From: Niels Holch
Affiliation: Executive Director, Coalition of Mutual Fund Investors

October 12, 2012

I dialed into today's telephonic meeting of the Investor Advisory Committee, as a member of the public. I also viewed the webcast of the Committee's meeting on September 28, 2012.

The Committee needs to be more transparent about what it is working on. The formal notice for today's telephonic meeting was only issued a few days ago. No detailed agenda for the meeting was prepared, and the JOBS Act recommendation paper from the Investor as Purchaser Subcommittee was not distributed to the public. It was difficult to follow the discussion in the meeting without having access to the same documents that the Committee members were reviewing.

It is very unclear what each of the Subcommittees is working on and whether there will be an opportunity for public input before individual recommendations are finalized. Except for a list of topics that was described in each of the Subcommittee reports at the September 28 meeting, the investing public is in the dark about what is going on in these Subcommittee discussions.

I understand that it may be beneficial for some Subcommittee deliberations to be conducted via non-public meetings and calls. But written proposals and agendas should be posted on the SEC website so that members of the public can participate in the Subcommittee and Committee deliberations through comment letters and emails.

If there is little interaction with retail and other investors not on the Committee, I question whether this Advisory Committee is really fulfilling its mission representing investor interests.