Sent: Tuesday, February 17, 2004 9:50 AM

Subject: Request for extended comment period on proposal File No.
S7-06-04 (confirmation & POS requirements)

You have recently published for comment Proposed Rule: 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.

The Commission requested comments by April 12, 2004.

A brief review of this proposal has led us to conclude that this proposal
could have as broad an effect on retail broker-dealers as the recently
enacted Books and Records rule modifications. In fact, in respect to the
proposed point of sale elements, fundamental changes in order receipt
procedures would be in order. We are of the opinion that we should ensure
that any such changes are well thought out and that all market participants
be given an opportunity to thoroughly review and then comment on the
proposal. For this reason, 1st Global respectfully requests that you extend
the comment period on this rule proposal to July 12, 2004 so that all
interested parties can be given an opportunity to effecting analyze and
offer a critique of the proposal.


Michael A. Pagano
Chief Compliance Officer
1st Global, Inc.
8150 North Central Expressway, Suite M-1000 
Dallas, TX 75206
(214) 378-0303 
(214) 378-0388  (fax)