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Johnsen Submits Comment Letter to SEC

Professor Bruce Johnsen has submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed Guidance Regarding the Duties and Responsibilities of Investment Company Boards of Directors with Respect to Investment Adviser Portfolio Training Practices.

In his comments, Johnsen confirms his support for the SEC's goal of providing clarity to fund boards in monitoring their advisers' use of soft dollars but expresses his concern that neither the SEC's 2006 Guidance nor its proposed Guidance recognizes the economic function of soft dollars, thereby not providing the clarity market participants deserve. Johnson points to his research supporting the idea that soft dollars ameliorate, rather than aggravate, conflicts of interest in mutual fund management.

Read Johnsen's Letter of September 30, 2008, to the SEC