From: Jeff Shamis
Sent: March 29, 2005
Subject: File No. S7-06-04

Jeff Shamis
8224 SW 103 Ave
Gainesville, FL 32608

Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Jonathan Katz:

I''m a fee-based financial planner who recommends mutual funds & variable insurance/annuity products to my clients when appropriate to implement/maintain their financial plans.

I'm writing to urge you withdraw the proposed disclosure requirements as proposed by the SEC (re sales of mutual funds & variable products) as redundant with existing requirements and therefore burdensome, confusing, costly, and unnecessary.

Prospectuses for these products already discuss relevant fees, risks and expenses as required. Regulators & industry have strived to simplify prospectuses in recent years; inadequacies (if any) should be addressed in the prospectuses, rather than developing new/additional materials.

Requiring a disclosure that focuses on investment fees & expenses without any mention of possible benefits of the product(s) may be as misleading to the investing public as it would be to discuss returns & performance without mentioning fees & expenses (& risks).

In summary, I urge you to withdraw the proposed rule.

Thanks for considering my views.


Jeff D. Shamis