Subject: File No. S7-11-04
From: Frank Palazzo

March 18, 2004

In that it appears that mutual fund violations have been committed by mutual fund managers in concert with large organizations, regulations, existing or proposed, should be imposed upon those entities. Proposing to penalize individual investors who desire to utilize a short term strategy of mutual fund investing with a two percent penalty for short term investing only serves to damage the parties the SEC is purportedly attempting to protect. This is especially applicable if an individual investor makes a mutual fund investment only to see the fund net asset value diminish substantially in the following day or two, redeems the diminished investment, and then has their loss compounded by an additional penalty from the SEC.