From: james curtis [jimc828@hotmail.com]
Sent: Thursday, December 12, 2002 9:16 AM
To: rule-comments@sec.gov
Subject: rule-comments (s7-51-02)







TOPIC:  Opposition to proposed mutual fund reporting guidelines

TO WHOM IT MAY CONCERN:  As a long-time mutual fund investor with a number 
of major fund companies, I strongly oppose the recent SEC proposal to 
require fund managers to disclose fund holdings quarterly. (Reported in the 
Wall Street Journal 12-12-02)

I view the proposed rule as detrimental to my fund managers' ability to 
acquire or sell positions in companies in a discreet manner over time while 
acting on behalf of my financial best interest. Managers of large funds are 
already at some disadvantage over individual traders in the market and this 
proposed change would only serve to put them at more of a disadvantage.

Further, it is ludicrous to assume that mutual fund investors are so 
short-sighted as to base long term investment decisions upon quarterly 
fund-holdings!   I, like most informed mutual fund investors, have a 
long-term time horizon---measured not in months or years, but in decades.  I 
have thoroughly researched both the mutual fund companies with whom I do 
business and the fund managers whom I have, in-effect,  hired  to manage my 
retirement assets.

Current rules for semi-annual disclosure are more than adequate. Please 
resist the political temptation to further ham-string fund managers. 
Instead, focus your energies on educating the public about the need for 
diversification in their fund selection and the importance of adhering to a 
long-term strategy tailored to their time-horizon and risk tolerance.

Finally, is it not a bit disingenuous of a mutual fund company best known 
for promoting  index funds to come-out in favor of rules changes which would 
serve to disadvantage more active fund managers?

Sincerely, James G. Curtis
jimc828@hotmail.com
04910 Lakeshore Dr.
Charlevoix, Mi. 49720

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