From: Richard W. Budman [rbudman@mscmail.biz]
Sent: Thursday, May 06, 2004 3:25 PM
To: rule-comments@sec.gov
Subject: S7-09-04

Re: The Proposed Rule in Release No. IC-26356



Dear Sirs:



Rule 12b-1 has allowed shareholders of mutual funds to receive ongoing 
professional services. A very positive development has occurred over the years 
since the adoption of Rule 12b-1 which I believe is of substantial benefit to 
fund shareholders especially with relatively smaller mutual fund investments. 
The receipt by broker-dealers and 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 cost 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.



Without the 12b-1 Fees I would not be able to provide these services to fund 
shareholder clients at all or without imposing charges for these services. In 
fact, at this stage in my business it is most likely I would be forced out of 
business, thus leaving the shareholders no one to turn for advice or service. 
I would not churn accounts just to make commissions in order to afford to stay 
in business.



Sincerely,



Richard W. Budman, CLU, ChFC

101 South 17th Street (Lower Level)

Allentown, PA 18104



Richard W. Budman, CLU, ChFC

Phone (610) 820-0240

Fax (610) 820-5011

Website - www.budmanconnors.com