February 21, 1990
TO: SEC RULES COMMITTEE NO. 14-90
ACCOUNTING/TREASURERS COMMITTEE NO. 6-90
OPERATIONS COMMITTEE NO. 4-90
ADVERTISING SUBCOMMITTEE
RE: DRAFT COMMENT LETTER ON PROPOSED REVISIONS TO FORM N-1A
__________________________________________________________
Attached is a copy of the Institute's draft comment letter
on the proposed revisions to Form N-1A. The Institute's comments
on the proposals are summarized on pages 2-4 of the attached
draft.
As you know, the Commission has proposed significant
disclosure items for mutual fund prospectuses such as disclosure
of the fund's past investment performance and of the fund's
portfolio managers. We believe that in this instance the
industry would have a greater impact if the Commission received
letters from individual fund groups. We therefore encourage you
to file your own letters on these proposals and, where
appropriate, to include detailed examples of the potential
problems the proposals create for your funds (e.g., picking an
"appropriate securities index" for comparison with your fund's
performance, disclosure of portfolio managers where a "team"
approach is used).
The comment period for the proposed revisions ends on March
12, 1990. It is therefore essential that I receive any comments
that you may have on the attached draft by March 2, 1990. My
direct line is 202/955-3523.
Amy B. Rosenblum
Assistant General Counsel
Attachment