From: Jane Riley [jane@leadersgroup.net]
Sent: Thursday, March 11, 2004 4:41 PM
To: rule-comments@sec.gov
Subject: Comment letter file No. S7-06-04

Jonathon G. Katz, Secretary
Securities and Exchange Commission
450 Fifth St., NW
Washington, D.C.   20549-0609


RE:  Release Nos.  33-8358; 39-49148; File No. 57-06-04

Confirmation Requirements and Point of Sale Disclosure Requirements for
Transactions in Certain Mutual Funds and Other Securities, and Other
Confirmation Requirement Amendments, and Amendments to the Registration Form
for Mutual Funds
File No.:   S7-06-04
Release Nos.:   34-49148; IC-26341
Comments Due:   April 12, 2004

Dear Mr. Katz:

Our broker/dealer is an independent “introducing broker/dealer” serving the
financial planning and insurance oriented registered representative.

The matters at hand now are the proposed “point of sale” disclosures and
post-sale confirmations.  The essence of these proposed rules are that the
registered representative will deliver to the mutual fund investor a “point
of sale” example of the commissions paid by the investor, the concession
paid to the broker/dealer, and a break out of the ongoing fees charged by
the fund company and fees paid to the broker/dealer, including what you
refer to as “soft dollars”.  Once the customer’s investment is finalized, a
confirmation will be required giving the investor specific numbers regarding
their investment.

Effectively, you are asking that our representative deliver fund specific
information at the point of sale, then the broker/dealer must deliver
investment specific information after the sale.  We have always had a
requirement to deliver a prospectus prior to the sale and the fund company
has had a requirement to deliver a statement to the investor after the sale.

We do not have a problem with enhanced disclosure to the investor since it
will add to investor confidence in the fairness of our investment
marketplace as a whole.  What does concern us about the proposal as written
is that it seems to be directed at the broker/dealer with no requirements on
the fund sponsors to provide the point of sale information or the post sale
disclosure in a uniform manner.

Please consider this correspondence as a request that you extend the comment
period at least 120-days; and that you more clearly specify how the mutual
fund companies will be required to provide the information necessary for the
point of sale disclosure and post sale confirmation in a uniform manner.

We also request that you include the two primary independent broker/dealer
industry associations in your discussions with industry members.  The
Financial Services Institute (FSI) and the National Association of
Independent Broker/Dealers (NAIBD) are actively involved with broker/dealers
such as ours and are in position to represent us effectively.  These
associations can be reached at www.financialservices.org and www.naibd.com.

Thank you for your time and consideration of this correspondence,

Z. Jane Riley
Compliance Officer
The Leaders Group, Inc.
Member NASD/SIPC