[16761]
November 11, 2003
TO: SMALL FUNDS COMMITTEE No. 29-03
RE: SEC INFORMATION REQUEST LETTERS
At the meeting of the Small Funds Committee last week, the Committee discussed
several issues related to recent allegations of late trading and market timing abuses involving
mutual funds. Among other things, members discussed steps they are taking in response to
these matters, such as conducting internal investigations. One member noted that the
information request letters that the Securities and Exchange Commission sent to various large
mutual fund complexes in September can serve as useful tools by providing a framework for
reviewing current policies and practices in these areas. Members requested that the Institute
send copies of these letters to the Committee.
Pursuant to that request, attached are two samples of these letters. The first letter
addresses policies and procedures related to market timing, late trading, and disclosure of
portfolio holdings. The second letter concerns pricing policies and procedures for securities
that trade in non-U.S. markets.
Frances M. Stadler
Deputy Senior Counsel
Attachment (in .pdf format)