Subject: File No. S7-11-04
From: De Alcorn

March 13, 2004

Some funds such as Rydex are set up specifically to handle short term or timing trades. They should be exempt from such fees.

Also it is not clear to me that mutual funds incur a cost of 2 percent for timing trades. This smacks of mutual funds adding costs for their benefit, and not their customers. The whole fee structure of mutual funds is suspect to me. Why not let the individual mutual fund set such fees after demonstrating they are justified, and so inform the customer.

It is also not clear to me why it is necessary for the SEC to impose a rule for such action.