Sent: Monday, February 23, 2004 12:35 PM
Subject: File No. S7-06-04

Proposed "point of sale" disclosure forms are good step, but don't
go nearly far enough.  The investor is due a candid and complete
disclosure of the fund's transaction fees -- brokerage fees
incurred as stocks and bonds are bought and sold.  At $30-50 a
pop, that hypothetical $8000 investment could get chewed up in
just a year or two.  And, disclosing "churn rate" or "turnover
rate" is not enough -- the prospective investor needs to see the
dollar outflow.  Finally, the investor needs to see a NAV adjusted
daily to reflect dollar outflow to turnover expenses.  It's not as
though the fund doesn't have the cost figures, and it's not as
though NAV weren't calculated in a matter of minutes after the
bell -- it's just that SEC has never acted to protect investors in
this sensitive area.  It is now time to act!!


Charles G. Scouten, Ph.D.                Phone: 630-428-1075
The Fusfeld Group                            Fax: 630-428-2463
29W528 Forestview Drive                  Email: cscouten@aol.com
Warrenville, IL 60555-2101                URL:  www.fusfeld.com