Investment Company Disclosure Initiatives (Audit No. 421)

-- MEMORANDUM September 25,2007 To: Andrew Donohue From: Nelson Egbert Investment Company Disclosure Initiatives (Audit No. 421) Re: Attached is our audit report on IM's Investment Company Disclosure Initiatives. IM's comments on prior versions of the draft report have been incorporated as appropriate. We would appreciate receiving any additional comments you have concerning this audit and the report. In particular, we would like to know whether you found the useful. We also welcome any suggestions from you concerning how we could improve future audits. The courtesy and cooperation of you and your staff during this audit are appreciated. Attachment cc: Susan Nash Brent Fields Donna Hawkins Jennifer McHugh Thomas Smith Jr. Diego Ruiz Ken Johnson Darlene Pryor Peter Uhlmann Richard Hillman, GAO INVESTMENT COMPANY DISCLOSURE INITIATIVES EXECUTIVE SUMMARY We found that the Office of Disclosure Regulation (ODR) in the Division of Investment Management OM)has identified goals and milestones for improving mutual fund disclosure and has made progress toward achieving itsgoals. ODR has developed and implemented rules that encourage mutual funds to submit financial and risk/rturn summary information in an interactive data language (extensible Business Reporting Language or XBRL). In the near future, ODR plans to finalize a proposal to further reform mu tual fund disclosure and delivery of infor ma tion to investors. We are recommending tha t ...