Subject: File No. S7-06-04
From: Ronald A Guiler

March 1, 2004

The proposed changes by the SEC will create much cost to the compliance and correspondence associated with the disclosure required with all clients. We already disclose these things to the client. In additon, if the 12b1 fees are eliminated there is no way we can stay in business and service the existing client base or new client base causing a grave dis-service to the investing public. I need additional time to digest the proposed amendments and to respond as well.