Date: 8/16/98 12:24 PM Subject: Proposed Rule S7-22-98 covering Transfer of Investment Advis I have only one specific objection to the approval of the rule. I think shareholders of the fund should be required to be spared the burden of paying for soliciting the shareholder approval of the transfer. I also suggest that shareholders of closed end funds be offered the opportunity to vote on the conversion of the closed end fund to an open end format when the investment management contract is being sold. This would allow the fund shareholders to express an opinion about the transfer of the contract and if opening were approved would allow disgruntled shareholders the opportunity to reinvest all their capital in a situation where they are choosing the investment advisor rather than being presented with a fait accompli. Gary Hall