From: Mike Heller [mike6heller@earthlink.net] Sent: Monday, March 29, 2004 12:21 AM To: rule-comments@sec.gov Subject: Comments - File S7-06-04 As an individual investor, I wanted to offer a few comments in this matter. I believe that complete disclosure, as proposed, is most important at the confirmation stage. Abusive compensation practices, etc., once known to the investor, will result in no repeat business. This also addresses the question of what sort of "pos" disclosure is practical in certain cases, such as when an ETF purchase is initiated over the telephone. Regarding variable annuities, I think the proposed rules should definitely apply, as the insurance industry, even more than the general securities field, has more than its share of sleight-of-hand sales people. Generally speaking, I think more different types of securities should be covered by the proposed rules, rather than less. Regarding front-end loads, you could require a percent figure to be disclosed. For back-end loads, you could require three figures, plus a sentence of explanatory text. The three figures would be (1) the nominal percent load, (2) the equivalent percent, with respect to the amount of the original investiment, if the final investment were 50% more than the initial investment, and (3) the equivalent percent, with respect to the amount of the original investiment, if the final investment were 50% less than the initial investment. For example, for an initial $1000 investment, if the back-end load were 5%, the first figure would be 5%, the second figure would be 7.5%, and the third figure would be 2.5%. The explanatory text would need, perhaps with a simple figure, explain that the 5% back-end load will be applied to the final amount, which may be more or less than the original amount. Regards, Mike Heller 330 Jacaranda Drive Danville, CA 94506