Subject: File No. S7-06-04
From: david m dass

February 20, 2004

Dear Sir/Madam:
As a former stockbroker and current financial services professional I would encourage you to disallow 12B-1 fees. For disclosure purposes: I have been a broker/manager for both Edward Jones and Merrill Lynch and have never had a complaint on my NASD record in 22 years.
12B-1 fees have never worked the way that the system was intended: to let economies of scales work to lower overall fees of fund investors. They are 2-3 times higher than when the fees were first allowed. 90-95 of individual investors dont know what fees are in their mutual funds.
Just read Jack Bogles speeches regarding 12B-1 fees. He can deliever a much more detailed and comprehensive argument for bannning 12B-1 fees than I can.
Please have some backbone and standup for the individual investor. Until fees are displayed each and every month/quarter on statments, IN DOLLAR AMOUNTS, the investor is not being given full disclosure.
David M. Cass