From: William J. Irish
Sent: March 31, 2005
Subject: File No. S7-06-04

Dear Mr. Katz,

I am a professional sales person and am liscensed to sell Mutual Funds as well as Variable Annuities. I am writing to voice my opposition to the proposed additional disclosure of fees and commissions of variable products as well as Mutual Funds.

With current SEC paperwork as well as issues imposed by the Patriot Act my clients are overwhelmed by the paperwork necessary to open a simple $3000 IRA as well as other equity based products. In 2002 the SEC reviewed and subsequently simplified the Prospectus in an effort to make the document more understandable to consumers. As you well know the Prospectus contains all the disclosure you are proposing to duplicate. It is simply unnecessary.

In addition, I fear that unnecessary disclosure would give rise to conversation of illegal rebates or kickbacks at the point of sale and highlight the costs without regard to the benefits of the vehicles involved.

There is already too much paperwork. Instead of professional advisors we are fast becoming a brigade of compliance monkeys. The paperwork is overwhelming small, independent advisors to the point of evaluation as to whether or not we can afford to stay in business. Please help.

Cordially William J. Irish