David S. Ruder, the former chairman of the Securities and Exchange Commission, who has been working as an independent consultant for embattled Strong Financial Corp., recommended the firm implement 2% redemption fees and send warning letters to Strong fund trader who buy and sell shares within a 30-day window. The company said it agreed.

Ruder took it a step further, saying if an investor conducts more than one buy-and-sell in a fund within a 30-day window, that individual should be barred from investing with Strong for a minimum of two years.

Strong chairman and CEO Kenneth J. Wessels said: "These compliance measures are intended to protect long-term investors in the Strong Funds. They do so by further deterring frequent traders from using the funds, by removing any investor who is investing in a manner that may be inconsistent with the interests of all fund investors, and by enhancing the process with respect to the fair valuation of all portfolio securities."

Ruder also suggested that the company hire a chief compliance officer that reports not only to Strong’s board of directors but also the independent Strong fund board.

The former SEC chief has been retained by Strong amid a market timing scandal that has led to the resignation of company founder Richard Strong for trading improperly in his own account. Ruder said his review will go on, and these are only initial recommendations.

Additionally, New York Attorney General Eliot Spitzer said that the firm has made as much as $600,000 over a five-year period through improper trading.

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