January 5, 2000

Room H-159
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Re: Advisory Committee on Online Access and Security -- Nomination, P004807

Dear Mr. Clark:

On behalf of the Investment Company Institute, the national association of the mutual fund industry, I write to nominate Alexander Gavis for appointment to the Federal Trade Commission’s Advisory Committee on Online Access and Security ("Advisory Committee"). Mr. Gavis is an exceptional candidate for selection to the Advisory Committee and would bring an important perspective to the Committee’s deliberations.

Mr. Gavis serves as assistant general counsel to Fidelity Investments, the nation’s largest mutual fund and a leader in the delivery of financial products to consumers through technological innovation. As the company’s chief legal counsel on electronic commerce issues, Mr. Gavis is responsible for providing counsel for virtually all of Fidelity’s internet-based businesses. He is also responsible for developing Fidelity’s policy relating to the handling of customer data and sensitive personal information. He is an expert on electronic commerce and has written extensively on legal technology issues involving the delivery of financial products via electronic means.

The success of the mutual fund industry is dependent upon the confidence of its shareholders in the products it provides and, equally as important, in its ability to protect the confidentiality and security of their personal information. As a representative from the mutual fund industry, Mr. Gavis would be able to share with the Committee the views and experiences of an industry that has a keen interest in data access and the protection of consumer privacy in electronic commerce. Moreover, the unique structure and operation of mutual fund organizations, and the sheer volume of shareholders our industry serves, would allow Mr. Gavis to provide a perspective to the Committee’s deliberations that will enhance its ability to develop informed fair information practices for commercial Web sites.

I ask that you give Mr. Gavis’ nomination every consideration. His high level of experience and knowledge would allow him to contribute significantly to the Advisory Committee’s deliberations. Should you have any questions, please do not hesitate to contact me or David Kemps of my staff at (202) 371-5406.


Matthew P. Fink,
President, Investment Company Institute


1. The Investment Company Institute is the national association of the American investment company industry. Its membership includes 7,932 open-end investment companies ("mutual funds"), 495 closed-end investment companies and 8 sponsors of unit investment trusts. Its mutual fund members have assets of about $6.160 trillion, accounting for approximately 95% of total industry assets, and over 78.7 million individual shareholders.