SEC's Report Provides Useful Information On Mutual Fund Fees And Recommends Improved Fee Disclosure

This correspondence (1) discusses the Securities and Exchange Commission's (SEC) report on mutual fund fee disclosures and (2) reviews SEC's response to GAO's recommendations on improving fee disclosure. The results of SEC staff's comprehensive analyses and other findings generally corroborate the findings of GAO's report and provide considerable additional information on the trend in mutual fund fees. The SEC staff's report also contains several recommendations to the agency's Commissioners, and the Commission has already approved recommendations on after-tax return disclosure and fund governance. In response to GAO's recommendation that mutual fund investors' quarterly account statements disclose the specific dollar amount of fees they paid, SEC staff recommends that investors receive additional fee information in funds' annual and semiannual reports. The SEC staff's proposal would provide investors with more information on fees in a form that allows comparison among funds. However, it will not provide information specific to each investor, nor will it be provided in the most frequent and relevant source--the quarterly statement. Therefore, it may be less likely to increase investor awareness and spur additional price competition among mutual funds to the same degree as GAO's recommendation sought to do.