Buyside Research_____
investment analysis_through technology
November 13, 2002
The Securities and Exchange Commission
450 Fifth Street, NW
Washington D.C. 20549
Re: Comment on the frequency of disclosure of mutual-fund holdings
Commissioners:
Buyside Research endorses quarterly reporting of mutual fund holdings. Buyside Research also suggests the Commission consider modifying disclosure regulations to require that these holdings be identified by CUSIP number.
Commonly, the text descriptions of N-30Ds (an example of the files I refer to, maintained on the Commission's web site, would be http://www.sec.gov/Archives/edgar/data/36405/000093247101500324/0000932471-01-500324-index.htm) do not clearly identify all of the issues owned by a fund. With no specific reference to the file referenced as an example, these records often do not distinguish between classes of stocks, whether the issue is common or preferred, if there is a dividend rate distinguishing issues, etc. CUSIPs have been designed specifically to avoid this kind of confusion, are universally employed by mutual funds and are easily appended to these records.
Only when mutual fund holdings are identified by their CUSIP numbers will the Commission's purpose for holdings disclosure, semiannual or quarterly, be achieved.
Thank you for your consideration.
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