Based on the results of this research, the Institute's supplemental comment letter recommends that the Commission adopt the ten-year bar graph and more focused narrative disclosure requirements. In addition, the letter urges that the Commission avoid the pitfalls of a mandated, numerical risk measurement.
Investors find narrative disclosure useful to their evaluation of risk.
Graphic presentation also would help investors. Quantitative risk measurements would complicate an evaluation of mutual fund risk for most investors. Quantitative risk measurements have a strong potential to confuse or mislead investors.