Announcements / Late Trading and Market Timing
January 2003
On September 3, 2003, New York Attorney General Eliot Spitzer announced the settlement of a complaint against Canary Capital Partners, a New Jersey-based hedge fund, for alleged actions involving a few mutual fund companies. The mutual funds advised by Dimensional (the "Dimensional Funds") were not named in the complaint, nor have we been contacted by the New York Attorney General's office for information.

As widely reported, the New York Attorney General has outlined alleged practices by certain mutual fund firms, including allowing late trading and engaging in collusive market timing arrangements. These practices are not and have never been allowed at Dimensional.

The Securities and Exchange Commission (the "SEC") has also delivered a letter to the 80 largest fund complexes, including the Dimensional Funds, requesting certain information relating to market timing, late trading and other practices alleged of others in the New York Attorney General's complaint. In addition, the SEC has issued a second letter to fund complexes that hold international securities, including the Dimensional Funds, requesting information relating to fair value pricing of international securities. To be clear, these requests for information in no way imply any wrongdoing by the Dimensional Funds or any of the other fund companies. We support these efforts by the SEC to protect the interests of all mutual fund investors.

Dimensional has a well-earned reputation for protecting the interests of long-term shareholders, and has always followed practices designed to prevent trading activity that would be detrimental to long-term shareholders. Only those trades received before the 4:00 p.m. (Eastern) market close may receive that day's closing price. These rules apply to shareholders who own Dimensional Funds directly, as well as to trust and custodian firms that have accounts with Dimensional on behalf of individual and institutional investors under contract. We have no reason to believe that there has been any effort to circumvent our trading time restrictions.

We monitor for suspected market timers or other short-term investors in the Dimensional Funds. On past occasions, we have declined to accept money from investors if we believed that the potential investors intended to employ the Dimensional Funds for short-term or speculative purposes.

Of course, we will provide the information requested by the SEC. In the meantime, we will remain vigilant to any transactional activity that could cause harm to our shareholders and take further appropriate actions designed to ensure that their interests continue to be protected.