MessageFrom: Hunt, Kevin [khunt@oldmutualus.com]
Sent: Friday, December 19, 2003 3:35 PM
To: rule-comments@sec.gov
Subject: File No. SR-NSCC-2003-21

December 18, 2003

Mr. Jonathon G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re: SR-NSCC-2003-21

Dear Mr. Katz:

Old Mutual Asset Management strongly supports the above referenced filing 
by National Securities Clearing Corporation (“NSCC”) to establish a 
Separately Managed Accounts (“SMA”) Service to improve the communications/
data flow among money managers and sponsor firms within the SMA industry.  
We concur with the recent filing by The Money Management Institute (“MMI”), 
our industry’s national trade organization, and believe MMI has accurately 
stated the benefits of NSCC’s proposed service.

Importantly, Old Mutual Asset Management believes NSCC’s proposal will 
stimulate competition within the SMA industry and benefit every firm doing 
business in this sector by bringing standards, developed by MMI for 
transmitting investor accountant information, into a streamlined 
communications system.  

We are aware that some vendor firms currently providing communications 
services to sponsor and manager firms may claim that they will be 
disadvantaged by the NSCC proposed system and we believe this viewpoint 
is both shortsighted and unjustified.  NSCC has stepped forward with its 
proposal, at the request of The Money Management Institute, precisely 
because the current system is inefficient and unable to handle projected 
growth.

We believe NSCC’s system will enable more firms to enter this business as 
money managers, as sponsors and as service providers to both managers and 
sponsors.  More competition will result and we welcome competition’s benefits 
and, accordingly, urge the SEC to approve the recent filing by NSCC.

Sincerely,

Kevin M. Hunt
Chief Sales and Marketing Officer