| Fund Democracy |
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Chronological list of Documents The following is a list of Fund Democracy-related materials dating from April 2000 to Apr. 17, 2008: Fund Democracy, Consumer Federation of America, Consumer Action and NASAA ask SEC for interpretive position that Sarbanes-Oxley whistleblower provisio n generally applies to fund manager employees (Mar. 28, 2008) (letter) Fund Democracy, the Consumer Federation of America, and Consumer Action comment on SEC proposal to permit mutual funds to use a summary prospectus to satisfy prospectus delivery requirement (Feb. 28, 2008)(letter) & (Apr. 17, 2008) (follow-up letter) Fund Democracy, the Consumer Federation of America, Consumer Action, AFL-CIO, Financial Planning Association, and National Association of Personal Financial Advisors petition SEC to require money market funds to file portfolios electronically with SEC (Jan. 16, 2008) (letter) Fund Democracy comment letter on SEC proposal to require electonic filing of exemptive applications under the Investment Company Act (Dec. 14, 2007) (letter) Study by Mercer Bullard, Geoff Friesen and Travis Sapp shows larger performance gaps for shareholders who buy funds through conventional distribution arrangements (Dec. 6, 2007) (study, Bullard statement) Fund Democracy and Consumer Federation of America letter commenting on SEC's proposed exemption from principal trading restrictions (Nov. 30, 2007) (letter) Fund Democracy and Consumer Federation of America letter to SEC regarding reproposal of rule relating to broker exclusion from definition of investment adviser (Nov. 2, 2007) (letter) Fund Democracy testimony before the Senate Special Committee on Aging on 401(k) fee disclosure (Oct. 24, 2007) (Testimony Statement Chart) Fund Democracy and Consumer Federation of America letter to DoL's Employee Benefits Security Administration regarding fee disclosure for individual accounts (e.g., 401(k) plans) (July 24, 2007) (letter) Fund Democracy testimony before Subcommitte on Domestic Policy, House Committee on Oversight and Government Reform regarding investment company status and regulation of hedge fund managers (July 11, 2007) (testimony) Fund Democracy releases preliminary memorandum on the status of Blackstone as an investment company (June 20, 2007) (letter) Fund Democracy and Consumer Federation of America write to OMB in support of DOL proposal to exclude capital preservation vehicles as qualified default investments (June 18, 2007) (letter) Regulator, consumer and adviser groups ask SEC to clarify brokers' legal duties in wake of court decision vacating the broker-dealer exemption (Apr. 24, 2007) (letter) Fund Democracy and Consumer Federation of America comment on SEC studies relating to fund governance proposals (Mar. 2, 2007) (letter SEC Economic Study: Power Study SEC Economic Study: Literature Review) Documents/links relating to Zero Alpha Group/Fund Democracy study finding that investors who buy funds through brokers pay a broker penalty in the form of being placed in funds with higher operating expenses (Nov. 30, 2006)(study Bullard press conference statement news release) Letter from Fund Democracy and the Consumer Federation noting that BISYS enforcement action further demonstrates need for the independent fund chairman rule (Oct. 18, 2006) (letter enforcement action) Letter from Fund Democracy and the Consumer Federation of America commenting on SEC proposal to require that mutual fund boards be 75% independent and have an independent chairman (Aug. 21, 2006) (letter) Letter from Fund Democracy and the Consumer Federation of America commenting on SEC draft request for proposals to conduct study of brokerage and investment adviser industries (July 19, 2006) (letter SEC Request) Supplemental letter to court from Fund Democracy and the Consumer Federation of America in connection with FPA challenge to SEC rule exempting brokers from regulation under the Advisers Act (June 28, 2006) (letter) Letter from Fund Democracy and the Consumer Federation of America commenting on the SEC Chairman's XBRL initiative (June 2, 2006) (letter SEC Chairman speech re XBRL initiative) Letter from Fund Democracy, Consumer Federation of America, Consumer Action, AARP and Consumers Union to SEC Chairman Cox urging a prompt request for comments on the costs of compliance with the independent chairman/75% independent board rule (Apr. 18, 2006) (letter) Amicus brief filed by Fund Democracy and Consumer Federation of America in opposition to SEC rule exempting brokers from regulation under the Advisers Act (Apr. 10, 2006) (brief) Letter from from Fund Democracy and Consumer Federation of America to SEC Chairman Cox regarding staff interpretation of broker exemption dated Dec. 16, 2005 (Feb. 15, 2006) (letter SEC staff interpretation) Comment letter from Fund Democracy and Consumer Federation of America regarding SEC interpretive release on soft dollar safe harbor (Nov. 23, 2005) (comment letter SEC interpretation) Amicus brief filed by Fund Democracy and Consumer Federation of America urging dismissal of Chamber of Commerce challenge to fund governance rules (Oct. 28, 2005) (amicus brief, press release: related third party documents: SEC brief, Chamber of Commerce brief, Court of Appeals decision) Letter from Consumer Federation of America and Fund Democracy to Chairman Cox regarding broker exemption (Sep. 30, 2005) (letter) Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union asking SEC to reject SIA's and ACLI's requests to extend compliance date for broker exemption (Aug. 11, 2005) (letter & SEC decision) Letter and press release from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union in support of Senator Akaka's Mutual Fund Transparency Act of 2005 (May 16, 2005) (letter -- press release) Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union responding to SEC request for comment on mutual fund point-of-sale document proposal (April 5, 2005) (letter -- original comment letter -- SEC request for further comment -- original SEC proposal) Fund Democracy and Consumer Federation of America response to letter from Chairmen Oxley and Baker to SEC regarding proposal to exempt certain fee-based brokers from adviser regulation (April 4, 2005) (letter -- Oxley-Baker letter) Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal to exempt certain fee-based brokers from adviser regulation (Feb. 7, 2005) (letter -- related letter on legislative history of the broker exclusion) Press Release from Fund Democracy, AARP, Consumer Federation of America, Consumer Action and Consumers Union on testing of mutual fund disclosure on point-of-sale document (Dec. 14, 2004) (press release) Letter from Fund Democracy, AARP, Consumer Federation of America, Consumer Action and Consumers Union on testing of mutual fund disclosure on point-of-sale document (Dec. 6, 2004) (letter) Testimony of Fund Democracy on 529 plans before the Subcommittee on Financial Management, the Budget and International Security, Senate Committee on Governmental Affairs (Sep. 30, 2004) (testimony) Testimony of Fund Democracy on financial products sold to military personnel before the the Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises, Committee on Financial Services, U.S. House of Representatives (Sep. 9, 2004) (testimony) Testimony of Fund Democracy before the Advisory Council on Employee Welfare and Pension Benefit Plans, Department of Labor (Aug. 5, 2004) (testimony) Statement by Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union regarding lawsuit filed by the Financial Planning Association challenging the SEC's proposed rule expanding the broker exclusion from the Investment Advisers Act (July 20, 2004) (statement) Testimony of Fund Democracy on 529 plans before the Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises, Committee on Financial Services, U.S. House of Representatives (June 2, 2004) (testimony) Comment letter from Fund Democracy and Consumer Federation of America on SEC proposal to require most mutual funds to impose a 2% redemption fee on shares sold within 5 days of purchase (May 11, 2004) (letter) Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal regarding mutual funds' use of brokerage commissions to finance distribution (May 10, 2004)(letter -- proposing release) Comment Letter by Fund Democracy and Consumer Federation of America on SEC proposal regarding disclosure of the basis of mutual fund boards' approval of the advisory contract (Apr. 26, 2004) (letter -- proposing release -- adopting release) Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal regarding fee disclosure in mutual fund point-of-sale and confirmation documents (Apr. 21, 2004)(letter proposing release) Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to SEC Chairman Donaldson regarding his testimony before the Senate Banking Committee on 4/8/2004 (Apr. 14, 2004) (letter) Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to Senate Banking Committee regarding testimony of SEC Chairman Donaldson dated 4/8/2004 (Apr. 13, 2004) (letter) Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to Senate Banking Committee regarding need for legislation (Apr. 7, 2004) (letter) Testimony on the need for mutual fund legislation before the Senate Committee on Banking, Housing and Urban Affairs (Mar. 23, 2004) (testimony) Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC request for comments on measures to improve disclosure of mutual fund portfolio transaction costs (Mar. 16, 2004) (letter) Rouge on a Corpse Won't Bring Mutual Fund Directors Back to Life, Jurist (Mar. 14, 2004) (article) Comment letter from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and Public Citizen on SEC proposal regarding investment company governance (Mar. 10, 2004) (letter proposing release adopting release) Letter to the Wall Street Journal from Fund Democracy and Consumer Federation of America responding to editorial by Fidelity Chairman Edward C. Johnson regarding SEC proposal to require an independent fund chairman (Feb. 18, 2004) (letter) Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding improving disclosure of mutual fund commission breakpoints (Feb. 12, 2004)(letter proposing release adopting release) Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal to require receipt of fund orders no later than the time the fund is priced (usually 4:00 pm est) (Feb. 6, 2004) (letter proposing release) Letter from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group to Senator Peter Fitzgerald in support of the Mutual Fund Reform Act (Feb. 5, 2004) (letter) Statement by Fund Democracy on Zero Alpha Group study on hidden fund portfolio transaction costs (Jan. 23, 2004) (statement) Alison Sahoo, Fund Titan: Mercer Bullard, Gadfly on a Mission, Ignites.com (Jan. 23, 2004) (article) Colin Dodds, Ignites Names Fund Titans for 2003, Ignites.com (Jan. 20, 2004) (article) Press release from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group regarding mutual fund reform issues, including SEC proposal to permit advisers to serve as subadvisers to mutual funds without shareholder approval (Jan. 12, 2004) (press release) Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding advisers acting as subadvisers to mutual funds without shareholder approval (Jan. 8, 2004) (letter) Press release from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group in connection with release of Blueprint for Mutual Fund Reform (Nov. 25, 2003) (press release) Blueprint for Mutual Fund Reform (Nov. 25, 2003) (press release blueprint) Testimony on the mutual fund scandal before the Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises, Committee on Financial Services, U.S. House of Representatives (Nov. 4, 2003) (testimony) Testimony on the mutual fund scandal before the Subcommittee on Financial Management, the Budget and International Security, Senate Committee on Governmental Affairs (Nov. 3, 2003)(testimony) Stephen Schur, The Good, Bad and Criminal Among Mutual Funds: Q&A With Mercer Bullard, TheStreet.com (Oct. 14, 2003) (abstract article). Investors Deserve an Intolerant SEC, TheStreet.com (Sep. 8, 2003)(article abstract) Press release from Fund Democracy and Consumer Federation of America regarding overpriced money market funds and index funds (July 23, 2003) (press release) Letter from Fund Democracy in support of amendment to H.R. 2420, The Mutual Funds Integrity and Fee Transparency Act of 2003, that would prohibit certain misleading fund names (July 22, 2003) (letter) Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union in support of H.R. 2420,The Mutual Funds Integrity and Fee Transparency Act of 2003 (July 9, 2003)(letter) Letter from Fund Democracy to House Subcommittee on Capital Markets following up on testimony dated 6/18/03 (July 9, 2003) (letter) Testimony of Fund Democracy before House Subcommittee on Capital Markets regarding The Mutual Funds Integrity and Fee Transparency Act of 2003 (June 18, 2003)(testimony) Letter from Fund Democracy, Consumer Federation of America, Investment Counsel Association of America, Financial Planning Association, certified Financial Planner Board of Standards, Inc., and the National Association of Personal Financial Advisors to SEC Chairman Donaldson regarding SEC proposal to expand the exemption for brokers who provide investment advice from regulation as investment advisers (May 6, 2003) (letter proposing release) Press Release issued by Fund Democracy, Consumer Federation of America, Investment Counsel Association of America, Financial Planning Association, certified Financial Planner Board of Standards, Inc., and the National Association of Personal Financial Advisors regarding letter to SEC Chairman Donaldson regarding SEC proposal to expand the exemption for brokers who provide investment advice from regulation as investment advisers (May 6, 2003) (press release) Letter from Fund Democracy, Consumer Federation of America, Financial Planning Association, Consumers Union, Consumer Action, U.S. Public Interest Research Group, Citizens Funds, Social Investment Forum, Domini Funds, National Association of Personal Financial Advisers, AARP, CalPERS, AFL-CIO, The Catholic Funds, CorpGov.net, and Robert Monks to Office of Management and Budget in support of SEC rule requiring mutual funds to disclose how they vote proxies relating to their portfolio securities (Mar. 6, 2003) (letter) Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding mutual fund portfolio and fee disclosure (Feb. 14, 2003) (letter) Statement of Mercer Bullard, Founder and President, Fund Democracy, at Pax World News Conference (Jan. 23, 2003) (statement) Comment letter from Fund Democracy regarding SEC proposal to require mutual funds to disclose their proxy-voting policies and records (Dec. 8, 2002) (second letter proposing release adopting release) Comment letter from Fund Democracy regarding SEC proposal to require mutual funds to disclose their proxy-voting policies and records (Oct. 21, 2002) (first letter proposing release adopting release) Statement of Mercer Bullard, Founder and President, Fund Democracy, at Pax World News Conference (Oct. 22, 2002) (statement) Bush, Congress Offer Solutions for the Wrong Enron Problem, Investment News (Feb. 18, 2002) (article) SEC Commissioner Saw the Future of Mutual Funds, TheStreet.com (June 16, 2001) (article abstract) The Mutual Fund Industry Sets the Record Straight, TheStreet.com (May 23, 2001)(article abstract) Proposed SEC Rule on Brokers Makes No Sense, TheStreet.com (May 15, 2001)(article abstract) SEC Staff Cuts Are Penny-Wise But Pound-Foolish, TheStreet.com (May 8, 2001)(article abstract) SEC to Mutual Funds: Take Down Your Arbitrage Welcome Signs, TheStreet.com (May 2, 2001) (article abstract) Advisers Need to Pick Up Warning Signs When Funds Court Trouble, Investment News (Apr. 30, 2001)(article abstract) Pay-to-Play in America, TheStreet.com (Apr. 26-30, 2001)(article: Part 1 Part 2 Part 3 Part 4 abstract) Maryland Self-Dealing Directors Law and Other Mutual Fund Issues, Tom Greeves' Fee-Only Radio Show (Apr. 17, 2001)(audio abstract) Testimony on Senate Bill 264 before the Committee on Economic Matters, Maryland House of Delegates (Mar. 28, 2001) (testimony) Mirror Mirror On the Wall, Is My Toad of a Fund Fairest of Them All? TheStreet.com (Mar. 27, 2001)(article abstract) Memorandum by Fund Democracy in support of rulemaking petition regarding more frequent portfolio disclosure, misleading fund names, and electonically accessible filing of information (June 28, 2000) (memorandum) Rulemaking petition by Fund Democracy regarding more frequent portfolio disclosure, misleading fund names, and electonically accessible filing of information (June 28, 2000) (petition proposing release adopting release) Testimony before the Committee on Economic Matters, Maryland House of Delegates regarding Senate Bill 264, which provides effective immunity for independent fund directors (Mar. 28, 2001) (testimony) Letter to SEC regarding applicant's response to Fund Democracy's request for hearing on exemptive application filed by Hillview Investment Trust for an exemption from section 15(a) of the Investment Company Act (Mar. 12, 2001) (letter) Request for a hearing by Fund Democracy on on exemptive application filed by Hillview Investment Trust for an exemption from section 15(a) of the Investment Company Act Request for a hearing by Fund Democracy on on exemptive application filed by Barclays to permit it to offer certain exchange traded funds (May 4, 2000) (hearing request) Pretty Please, Can We Sue You? TheStreet.com (Mar. 7, 2001)(article abstract) Memorandum in support of request for hearing by Fund Democracy on application to permit adviser to serve as subadviser to mutual fund without shareholder approval (Mar. 5, 2001) (memorandum) Request for Hearing by Fund Democracy on application to permit adviser to serve as subadviser to mutual fund without shareholder approval (Mar. 5, 2001) (hearing request) Another Chink in the Wall: SEC Grants Self-Dealing Exemption to Goldman Funds, TheStreet.com (Mar. 1, 2001)(article abstract) Voting Rights II: How Funds Raise Fees Without a Shareholder Vote, TheStreet.com (Feb. 15, 2001)(article abstract) A Voting Rights Issue that Hits Home for Investors, TheStreet.com (Feb. 13, 2001)(article abstract) Industry Trying to Defang Law Disclosing the Tax Bite on Fund Returns, TheStreet.com (Feb. 8, 2001) (article abstract) SEC Finally Moves to Stop Arbs Who Prey on Foreign Funds, TheStreet.com (Feb. 6, 2001) (article abstract) Despite SEC Efforts, Accuracy in Fund Names is Still Elusive, TheStreet.com (Jan. 30, 2001) (article abstract) From Worst to First: Jacob Internet Moves to Cutting Edge of Disclosure, TheStreet.com (Jan. 26, 2001) (article abstract) What's An Excessive Fee? Courts Leave it to Funds to Decide, TheStreet.com (Jan. 24, 2001) (article abstract) No Matter How You Slice Them, Mutual Fund Fees Should be Lower, TheStreet.com (Jan. 23, 2001) (article abstract) New Rules for Independent Directors Will Give Funds More Above-Board Boards, TheStreet.com (Jan. 17, 2001) (article abstract) It's Hard to Hide a 79% Loss, but Jacob Internet Is Trying, TheStreet.com (Jan. 16, 2001) (article abstract) Are Ballots Too Secret? Fund Advisers Should Tell How They Vote Proxies, TheStreet.com (Jan. 4, 2001) (article abstract) Make 2001 the Year You Become an Activist Fund Shareholder, TheStreet.com (Jan. 2, 2001) (article abstract) Folios: The Newest New Thing, Investment Advisor (Jan. 2001) (article) Letter to Charles Jaffe, Boston Globe (Dec. 28, 2000) (letter) SEC's Push for Disclosure Often Stops at Its Front Door, TheStreet.com (Dec. 21, 2000) (article abstract) Letter to Mutual Funds Magazine (Dec. 22, 2000) (letter) SEC Rejects S&P Move to Stall Vanguard's Vipers, TheStreet.com (Dec. 14, 2000) (article abstract) Activists, Advisors Press for Better Mutual Funds Disclosure, NAPFA Advisor (Dec. 2000) (article abstract) SEC May Hold Independent Directors Responsible for Heartland Debacle, TheStreet.com (Dec. 6, 2000) (article abstract) Heartland Fiasco Shows Need for Conflict of Interest Rules, TheStreet.com (Dec. 1, 2000) (article abstract) SEC Preparing to Shine a Brighter Light on Fees, The Street.com (Nov. 17, 2000) (article abstract) S&P Asks SEC to Block New Vanguard Viper Fund, TheStreet.com (Nov. 1, 2000) (article abstract) Be Aware of Fund Finagling, Mutual Funds (Nov. 2000) (abstract) Role Reversal, Investment Advisor (Oct. 2000) (abstract) Mutual Fund Portfolio Disclosure in the Internet Era, wallstreetlawyer.com (Sep. 2000) (abstract) SEC Prepares to Battle Portfolio Pumping and Window Dressing, TheStreet.com (Aug. 16, 2000) (article abstract) Misleading Fund Performance Claims? 'The SEC Made Me Do It,' TheStreet.com (July 15, 2000) (article abstract) International Funds Still Sitting Ducks for Arbs, TheStreet.com (July 1, 2000) (article abstract) Memorandum in support of petition for rulemaking to require mutual funds to: (1) use names suggesting that they invest in a particular type of security only if 85% of their assets are invested in that type of security; (2) publicly report their portfolio holdings on a monthly basis within 60 days after the end of each month, with exceptions granted by the Commission on a case-by-case basis, and (3) post portfolio holdings on the Internet in a format that is easy to download and analyze, and provide paper copies of this information upon request (June 28, 2000)(memorandum, subsequent release prohibiting misleading fund names rule, subsequent release requiring more frequent portfolio disclosure) Petition for rulemaking to require mutual funds to: (1) use names suggesting that they invest in a particular type of security only if 85% of their assets are invested in that type of security; (2) publicly report their portfolio holdings on a monthly basis within 60 days after the end of each month, with exceptions granted by the Commission on a case-by-case basis, and (3) post portfolio holdings on the Internet in a format that is easy to download and analyze, and provide paper copies of this information upon request (June 28, 2000) (petition, subsequent release prohibiting misleading fund names rule, subsequent release requiring more frequent portfolio disclosure) Your International Fund May Have the "Arbs Welcome " Sign Out, TheStreet.com (June 10, 2000) (article abstract) Barbarians at the Gate, On Wall Street (June 2000) (abstract) As 401(k) Plans Spread Information Gap Becomes More Glaring, TheStreet.com (May 27, 2000) (article abstract) The Fund Prospectus: Yesterday's News, SmartMoney.com (May 11, 2000) (abstract) Letter from Fund Democracy withdrawing request for hearing on ETF exemptive application (May 11, 2000) (letter) Letter supplementing Memorandum in Support of Hearing Request dated 5/4/00 regarding request for a hearing on ETF exemptive application (May 9, 2000) (letter) Memorandum in support of request for a hearing on ETF exemptive application (May 4, 2000) (memorandum) Request for a hearing on ETF exemptive application (May 4, 2000) (hearing request) Heads in the Sand, Barron's (Apr. 10, 2000) (abstract) |