Subject: File No. S7-06-04
From: Joel N. Williams

February 26, 2004

I have read many mutual fund prospectuses, and while most of them say that they are against market timing, I have never seen a definition of market timing. Is it selling after 2 days? Selling because you think the market is going to hell? Selling because of panic over a terrorist attack?

I think that it is partly because of this lack of definition of market timing that there have been problems. After all, the looser the rule, the easier to bend it for somebody with a lot of money.

I hope that your 5-day rule is used to define market timing, even though the rule, in itself, is somewhat arbitrary.

On a separate note, you need to enforce settlement rules. Most funds require 1-day settlement on a buy and also say that they give 1-day settlements on a sell. However, I am still waiting for Brown and Co. to credit my account for a sale 3 days ago. It is not Browns fault - the fund company has just caused a delay.

If I have to settle in 1 day, the company should also have to settle in 1 day. Please look into this.