From: []
Sent: Wednesday, April 28, 2004 8:43 PM
Subject: FILE # S7-09004: DON'T MONKEY WITH 12 B-1 FEES (S7-09-04)

To Whom it May Concern:

I am a licensed investment professional of 20 years and have been helping people make mutual fund investments for many years. I work with many small investors, putting small amounts away -- providing them with beginner education on risk, market fluctuation, time horizon and so forth. I help them develop a plan to make their dreams come true. I also counsel them during market downturns, personal financial tragedies and other circumstances where trusted advice is needed to prevent financial damage. I can think of no better example than the recent market downturn -- which lasted three years. Many, many clients called me, looking to sell when the market was at its lowest. I stood in front of the natural human urge to "get out while I still can".

I counselled them only to sell if they really needed the money -- and a few did, because personal and business setbacks required it. The vast majority heeded the advise and realized it would be at their own peril to follow the market momentum to sell.

Now most have recovered their "paper losses."

I humbly submit that the true service that I, and other trusted financial advisors like me, provide to our clients is a real value. And the huge losses prevented protected real family assets that dwarf the economic value of a .25% 12 B1 fee. My clients know this is the way I am paid to provide on-going service -- so they don't mind calling on me when they need me. I can't think of any enterprise anywhere in this great country of ours where we would expect anyone to work for nothing. And, in my opinion, the gains preserved -- and the dreams they provide -- make those fees look like next to nothing.

I would also submit that research will prove that the greatest losses incurred by investors losing faith and selling at the market lows occured with no-load, no broker and no 12 B-1 fee funds -- where they had nothing to guide them but a voice on an 800 number!

If there are unscrupulous brokers, they should be dealt with -- but those providing value to customers should not be punished for the sins of a very few.

David S. Spellman, President
Pratt Financial Group, Inc.
969 Main Street PO Box 439
Westbrook, Maine 04098
207 854 9745
800 427 9745
fax 207 854 2109

2003 Recipient, J. Putnam Stevens Award