Subject: File No. S7-28-07
From: Roy J Biegel

February 14, 2008

I strongly support your placement of expenses front and center in the summary prospectus. For keeping these low are critical for investor return. Portfolio turnover can have likewise effects.

There are 2 items glaringly absent from the proposal. Please add the relevant benchmark, such as SP 500, Wiltshire 5000,... If the Annual Total Return is compared relative to an index, that needs to be clearly stated and/or plotted beside the funds return. Also needed are the quantity of holdings. A fund with only 32 stocks is much more risky than a fund with hundreds or thousands of stocks.

One additional item I would like to see added is the amount Net Assets the fund has. Actively managed bigger funds are not as nimble as the smaller ones.

Commingled funds in 401k's should also be required to produce the same summary for individual investors.

I applaud your efforts.