Market Watch

[Mattu]

Damn, Joe. Sometimes you make us think you are schizo. You can write so well and be so dang intelligent. And other times....

Excellent letter though.




From: marketreporter [[e-mail]]
Sent: Wednesday, June 12, 2002 4:06 AM
To: marketreporter; [e-mail]
Subject: Rule Comments (S7-17-02) - .txt file attached

Comments on Rule: S7-17-02 "Proposed Amendments to Investment Company Advertising Rules"

To the Securities and Exchange Commission,

It has come to my attention that you have proposed a rule/amendment regarding the
SEC's policy towards advertising for investment companies. I personally, am glad that
such a matter has come to your attention, especially in such a weary market. The fact
that many, or perhaps all, investment companies lack the moral sense to disclose the
details behind their performance is a problem which causes many people to be misled into
services they would not otherwise be interested in, such as a high risk mutual fund.

A typical example of this would be an investment company advertising its mutual fund's
6 month performance from the date September 21, 2002 (post-9/11/02 low) to March 21, 2002.
During this time period, the Nasdaq gained approximately 31%. For the sake of argument,
we'll say that this mutual fund's gains ran parallel with the Nasdaq. The investment
company would then go and advertise it's 6-month, 31% gain either on television, in print,
or where ever else. The potential clients that would see this advertisement, would then
be falsely informed and would not know that the performance advertised by the company was
altered and such returns were not typical. The current disclosure used by most investment
companies "Past performance is no indication of future results," is not enough and does not
at all give details about the company's specific performance. My example may have been an
extreme case of such deception, but nonetheless, is still a reasonable and realistic case.
Other investment companies may not be as bold, but deception is deception, no matter how
extreme it is.

I personally, would like to see the SEC set a standard time period for advertising
performance. For example, all investment companies would be required to only advertise
their performance during an SEC approved time period, which the SEC believes is a
balanced period that would reflect average returns in the stock market. This would defeat
the altering of dates on investment time periods to improve market returns. An expert
SEC panel would analyze the market to choose a proper time period that would be fair and
average. Investment companies misleading investors should not at all be allowed.

I support your actions.

Thank You for your time,

Joseph M. Jaros Jr. a.k.a. Joemoney
Investor
President/CEO of MarketReporter.com
& United States Citizen