From: Joseph M. Letson
Sent: March 30, 2005
To: rule-comments@sec.gov
Subject: File No. S7-06-04


I am a licensed insurance professional and variable products salesperson. I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers.

I feel that the prospectus discloses all the fees necessary for a prospect to read and understand. Giving the client additional information on fees could add apprehension to a variable purchase. I feel most people understand there are going to be annual, set up, and fund fees for a purchase.

I urge the NASD to withdraw the rule regarding additional disclosure of fees.

Joseph M. Letson
Investment & Retirement Services
Kapnick & Co. Inc.