From: James B. Twining
Sent: March 31, 2005
Subject: File No. S7-06-04

The Point of Sale Disclosure rule will have negative consequences for my clients:

1) It will increase the cost of mutual fund and variable annuity investments

2) It will effectively limit the investment choices available to them

Please understand that the Prospectus is the disclosure document that must accompany any sale of a mutual fund or variable annuity. The Prospectus has all of the material information concerning these investments, including costs. THE PROSPECTUS IS THE POINT OF SALE DISCLOSURE DOCUMENT. If you want changes to the disclosures, make them in the prospectus.

Also please understand that unethical brokers and advisors push mountains of discosure documents in front of their clients and have clients sign them without reading them. No amount of additional disclosures will change that sad fact. On the other hand, ethical brokers and advisors disclose all material facts including costs, and they will continue to do so whether or not you create an additional disclosure document.

James B. Twining, CFP
Financial Plan, Inc.
Linsco/Private Ledger member NASD/SIPC