* See Memorandum to SEC Rules Committee No. 54-98 and Shareholder Reports Task Force dated June 5, 1998, and
Memorandum to Accounting/Treasurers Committee No. 24-98 dated June 9, 1998.
[10115]
July 10, 1998
TO: ACCOUNTING/TREASURERS COMMITTEE No. 28-98
SEC RULES COMMITTEE No. 71-98
RE: REVISED DRAFT LETTER TO SEC ON IMPROVING SHAREHOLDER
REPORTS
______________________________________________________________________________
Attached and summarized below is a revised draft of the letter from the Institute to Barry
Barbash of the SECGs Division of Investment Management suggesting certain changes to the forms of
annual and semi-annual reports. This revision is based on member comments to the June 5 draft that
was circulated for comment to the SEC Rules Committee, Accounting/Treasurers Committee and
Shareholder Reports Task Force.*
The revised letter contains several changes from the June 5 draft. First, the letter no longer
recommends elimination of the financial highlights table from shareholder reports. Instead, the letter
recommends that the financial highlights table be revised to: (1) eliminate the net investment income
ratio; (2) consolidate for non-money market funds the two line items detailing separate distributions per
share from net investment income and realized gains into a single line item captioned “distributions;”
and (3) eliminate the per share data for money market funds. Second, the letter now states that
shareholder reports should be drafted with “plain English” principles in mind (see page one).
If you have any comments on this draft, please contact either Joe Savage (telephone: 202/326-
5819, fax: 202/326-5839, or e-mail: savage@ici.org) or Greg Smith (telephone: 202/326-5851 or e-mail:
smith@ici.org) no later than Monday, July 27.
Joseph P. Savage
Assistant Counsel
Attachment