Subject: File No. S7-06-04
From: Rick Brooks, CFA, CFP

March 25, 2004

I have reviewed far too many investors portfolios who had no idea what they were paying in fees. These have ranged from retirees who owned annuity contracts with substantial commission payments to the selling broker inside of retirement or pension accounts to group annuity 401k plans where the annual contract expenses approached 2. Most retail investors, inlcuding many sophisticated high net-worth investors, have no idea how much their financial advice is costing them in total, and the additional disclosures proposed by the commission are absolutely necessary to restore their confidence in the system.

In fact, these disclosures will also help to improve the viability and fairness of the mutual fund supermarket platforms opperated by the likes of Charles Schwab and most other discount broker/dealers - IF REQUIRED OF THEM AS WELL.

Full and fair disclosure of fees has long been a requirement to obtain a mortgage, so that the borrow has detailed information about what the total costs of their loan will be. We should expect nothing less from other financial service providers, particularly those who rely almost entirely upon the trust of the investor in order to make a sale. While there is trust, with undisclosed conflicts of interest, there is too much room for abusive practices by aggressive sales-oriented firms.

While there are undisclosed conflicts of interest, it is not possible to assume that the financial professionals will ALWAYS act in the best intersts of their clients, rather than their own interests. These disclosures are a bare minimum, and represent a quantum improvement in the way in which we conduct our business.