Subject: File No. S7-12-08
From: Gary J Coles

July 25, 2008

The standard practice of reporting returns for the past 1, 3, 5 and 10 years...or similar reporting periods...does not permit prospective buyers to evaluate adequately a fund's performance relative to the market or its peers. That's because all these roll-up schemes all are based on the same It is highly desirable to have a fund ranked relative to the market and its peers on a calendar-year basis for each of the past five, or better yet, ten years. Consistent performance year-after-year provides a sound measure of how well a fund's managers are doing relative to others and does not unduly reflect recent performance.