Subject: File No. S7-09-04
From: Neal A. Thomas

April 9, 2004


I am writing in support of the continued use of 12b-1 fees as is currently used.

I think the fee is a bargain for my clients and allows me the means to provide service to them that is a value. We give ongoing service that we willingly provide because we are being compensated. I think the fee is quite insignificant from the clients point of view.

The success of the mutual fund field is inviting scrutiny from many who have political ambitions. We are so successful that we do in fact control a lot of money. Should be be punished for that success?

The fee allows us to be compensated and quite frankly we are less likely to find reasons to move money and entail new surrender charges and fees for the client since we are being compensated.

One of the biggest frauds in recent times is the no-load myth. There is no such thing, nor should there be. If I am receiving value I expect to pay for it. That is called free enterprise. Its a marvelous system. I fear that over-regulation may well stifle the system.