Subject: File No. 4-500
May 9, 2005
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street NW
Washington, DC 20549
Re: File No S7-11-04
Dear Mr. Katz:
In response to proposed legislation for a Redemption Fee rule, I would like to express two important issues. Both of these issues if not specifically addressed could hurt shareholders of mutual funds in the long term.
The first is that the redemption fees should not be imposed for systematic withdrawals for income, withdrawals due to hardships, or paying for third-party advisors. Withdrawal values for these items typically are insignificant to the fund assets and costs to the fund would seemingly be negligible.
The second is redemption fees should be related to a reasonable or actual cost incurred by the remaining shareholders should a withdrawal be made. There is much debate on whether these costs are significant.
Thank you for your consideration of these issues.
Mary K. Collins
Spectrum Financial, Inc.
2940 N. Lynnhaven Rd.
Virginia Beach, VA 23452
(757) 463-7600 www.spectrumfin.com
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