The Toward Truth In Mutual Fund Investing Symposium was held on Thursday, October 12, 2000, in Washington, DC. Fund Democracy extends its appreciation and thanks to the panelists who, on their own time and at their own expense, helped make this event a great success.

Paul Roye, Don Phillips, Harold Evensky, Davis Nadig, David Musto and Mercer Bullard engaged in a lively discussion about fund portfolio disclosure, misleading fund names, and related issues. Members of the audience were particularly appreciative of the wide range of views presented, with one describing the discussion as "absolutely riveting." The archived tape of the Symposium is available at MetaMarkets.com's Web site.

As reported at the Symposium, the National Association of Investors Corporation filed a petition with the SEC requesting rules requiring more frequent, online portfolio disclosure, and prohibiting the use of misleading fund names. The NAIC represents over 650,000 investors and over 36,000 investment clubs. You can view the NAIC's petition and press release at this site, as well as other documents related to the portfolio disclosure initiative.

The disclosure initiative also scored its first victory when Paul Roye announced that the SEC staff would recommend that the Commission adopt the misleading names rule. The SEC proposed the rule in 1997, after Congress passed legislation in 1996 that directed the SEC to adopt rules prohibiting misleading fund names. Under industry pressure, support for the rule withered. The proposal has been considered "dead" for years. The disclosure initiative has resurrected the rule, and Roye expects to take action on the rule by the end of the year.

With one request all but granted, the focus will now shift to the petitioners' other requests regarding the frequency and format of fund portfolio disclosure. Based on discussions with SEC staff, it appears that there is strong SEC support for quarterly, electronic portfolio disclosure. The Commission may have reservations, however, about whether monthly portfolio disclosure, even with a 60-day time lag before posting the information on the Internet, might run a risk frontrunning fund transactions by traders. Indeed, frontrunning is a serious concern, and the industry could greatly advance the debate by conducting and publishing an empirical analysis on whether a longer time lag, 90 days perhaps, is necessary if portfolios are required to be disclosed monthly.

In the meantime, the petitions will keep rolling in. If you would like to express your views, please send Chairman Levitt a message, or file your own petition and send it to:

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

re: SEC File No. 4-439

For articles related to the Symposium, see: Sara Hansard, Fund Disclosure Proponents Eye 401(k)s, Investment News (Oct. 23, 2000); SEC Will Adopt 80 Percent Name Rule, Mutual Fund Market News (Oct. 16, 2000); SEC May Tell Funds to Stick With Styles, Investment News (Oct. 16, 2000); Danny Hakim, Advocates of Fund Disclosure See Double Standard at the SEC, New York Times (Oct. 13, 2000); Joe Morris, Reg on Fund Names Due by Yearend, Ignites.com (Oct. 13, 2000); Catherine Valenti, SEC Demurs on More-Frequent Disclosure by Mutual Funds, TheStreet.com (Oct. 12, 2000); Phil McCarty, SEC to Adopt Mutual Fund Name Rule by Year-End, Dow Jones Newswires (Oct. 12, 2000); Vicky Stamas, SEC Expected to Take up Disclosure Rule for Specialized Funds, Bloomberg (Oct. 12, 2000).

Thank you for your interest.

Mercer Bullard