March 16, 2004
I think the proposal is excellent. I have three specific comments.
1 Attachment 1 displays in section B the Front end sales load, and in section C the Sales fee. It is not clear from the form whether the sales fee is included in the Front end sales load or whether it is in addition to the load. It would be clearer if you showed the total of all fees paid up front.
2 What about so-called no-load mutual funds? Does this apply to them? i.e. requiring full disclosure in advance of 12b-1 fees, and other expenses?
3 Most investors do not appreciate the impact of a front end load on the earning power of their investment. It would be very informative to display a chart or table of, for example, 10,000 dollars invested and earning 6 percent per annum compounded, vs. 10,000 dollars minus an 8 percent front-end load, earning 6 percent per annum compounded.