Subject: File No. S7-09-04
From: Greg LaPierre

May 5, 2004

Rule 12b-1 Has Allowed Shareholders to Receve Ongoing Professional Services - A very positive development has occurred over the years since the adoption of Rule 12b-1 which we believe is of substantial benefit to fund shareholders, particularly those shareholders with relatively smaller mutual fund investments. The receipt by broker-dealers and their representatives of 12b-1 fees has enabled these shareholders to receive ongoing professional services which would otherwise not be available to them or only available at additional costs to these shareholders.

These services include not only administrative services, such as providing, changing or correcting account information, but also substantive assistance through the provision of analysis and financial planning for these shareholders.

Thank you.