From: Everard Davenport
Sent: August 16, 2006
To: rule-comments@sec.gov
Subject: File No. S7-13-06


I appreciate the thought that went into the proposed 28(e) guidance. I have only one suggestion please require the companies to report all benefits they receive under this type arrangement to their institutional investors. There is no other way for us to know if we should be asking questions.

Everard Davenport
General Counsel
Dallas Police and Fire Pension System