Subject: File No. S7-11-04
From: Mike Lan

April 19, 2004

This is another one of those well-intended rules that is going to do the exact opposite. Its going to hurt the very investors that it is supposed to help, and generate more fees for the mutual fund companies. Surely anyone with a decent financial training can spot a market timer moving large amount of money in and out quickly. Why make it mandatory against all? If I invested in a fund that I later realized that it was a bad move, I would like the freedom to get out without paying any penalties. If this rule is enforced, people should simply invest in ETFs, not mutual funds.