From: Tom Robertson [tomrobertson@cfl.rr.com] Sent: Thursday, May 06, 2004 9:08 AM To: rule-comments@sec.gov Subject: S7-09-04: Prohibition on the Use of Brokerage Commissions to Finance Distribution I strongly believe that the adoption of Rule 12b-1 has been a substantial benefit to fund shareholders, particularly those shareholders with relatively smaller mutual fund investments. The SEC should understand that receipt by broker/dealers and their representatives of 12b-1 fees has enabled shareholders to receive ongoing professional services, which would otherwise not be available to them or only available at additional costs. These services include not only administrative services, such as providing, changing or correcting account information, but also substantive investment management assistance through the provision of analysis and ongoing comprehensive financial planning for these shareholders. L. Thomas Robertson, CFP DeLand, Florida