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Letter to the Securities and Exchange Commission Re: Mutual Fund Disclosure

Although we view this proposal as an improvement over the current woefully inadequate state of mutual fund disclosure, we are nonetheless forced to conclude that it is seriously flawed. As we will discuss in more detail below, the proposed disclosures fail to provide all the information mutual fund investors need about costs and conflicts, they fail to ensure that the information is provided at a time when it is likely to influence the purchase decision, and they fail to ensure that it is provided in a form that average, unsophisticated investor will easily understand. We therefore strongly recommend that the Commission adopt major revisions to the content, timing, and format of its proposed disclosures.

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