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ARTICLE · 17 MARCH 2004

SEC Proposes Additional Disclosure Regarding Portfolio Managers of Registered Funds

At its March 11, 2004 meeting, the SEC voted to approve a proposal (the "Proposal") that would require registered open-end and closed-end funds and insurance company managed separate accounts that issue variable annuity contracts (collectively "Funds") to provide additional disclosure regarding the portfolio managers of the Funds.

United StatesFinance and Banking

At its March 11, 2004 meeting, the SEC voted to approve a proposal (the "Proposal") that would require registered open-end and closed-end funds and insurance company managed separate accounts that issue variable annuity contracts (collectively "Funds") to provide additional disclosure regarding the portfolio managers of the Funds. The additional disclosure would include: (a) information about the members of portfolio management teams on the same basis as required for individual portfolio managers and (b) information about (i) other accounts managed by a Fund’s portfolio manager (collectively, "Other Accounts"), (ii) potential conflicts of interest arising from a portfolio manager’s Other Accounts and policies and procedures to address those conflicts, (iii) portfolio manager compensation structure, and (iv) portfolio manager ownership of securities of their Funds and Other Accounts. The Proposal would also eliminate the exclusion from the portfolio manager disclosure requirements

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