Subject: Proposed Regulation #17j-1
Author:  "Sebranek" <sebranek@aero.net> 
Date:    12/12/98 8:07 PM
     
     
Dear SEC:
     
Why not subject portfolio managers, investment analysts and etc. to the same 
rules that apply to registered representatives of broker/dealers?  They could 
provide duplicate copies of all brokerage account statements to the Board of 
Directors of the Investment Company, who would then have the responsibility (or 
a designated agent/compliance officer) for monitoring their investment activity.
 This would be more of an internal audit process.  Then, the SEC could randomly
audit the records of the Investment Companies to determine whether proper steps 
are being taken.  If procedures are lax or incomplete, then the SEC could levy a
fine against the company, the Board, and/or the employee.