In reviewing 'registrant filings' belong in the statement of additional information, not in the summary prospectus. At any event, the disclosures must comply with the SEC's plain English requirements.

Registrants should take note that they may be found liable for disclosing too much in the wrong places.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice that applies to particular situations.

* Jay G Baris is the chair of Morrison & Foerster's Investment Management Practice and a partner there. He can be reached at jbaris@mofo.com or on +1 (212) 468-8053.