From: Maribel Israel [maribel.israel@towersperrin.com] Sent: Monday, January 26, 2004 8:04 PM To: rule-comments@sec.gov Subject: New Confirmation and Point of Sale Disclosure Requirements Dear Sir or Madam: I applaud the SEC's efforts to propose new guidelines for mutual fund companies and the sale of fund shares. The ability to receive full disclosure regarding any and all expenses individual investors pay to mutual fund companies and investment advisers will be very helpful in our decision-making processes and make us better informed. The Department of Labor developed a table assisting plan sponsors in evaluating their retirement plan's overall plan expenses. I respectfully suggest that the SEC consider establishing similar data tables (such as the DOL's) be required disclosure to individual investors. One of the SEC proposals requires companies give investors information that would help them see how their particular mutual fund's costs and payments compare with those of similar funds. I respectfully suggest that the SEC specify that such disclosures of mutual fund expenses be made on funds of the same asset class. That is, the comparison of expenses should be made of like funds not dissimilar fund types otherwise investors would not be making apples-to-apples comparisons. Another of the SEC proposals requires investment advisers for mutual funds would have to adopt codes of ethics. I wonder how effective the enforcement of such policies will be. It would be helpful if the SEC could specify the penalties or other punitive damages an investment adviser or mutual fund company would incur if certain ethical practices are not followed. Otherwise, it seems to me that an investor is still assuming good faith compliance. Regards, Maribel Z. Israel 411 Fieldstone Drive Richmond, CA 94806 personal e-mail address: maribel@israel-family.org