Subject: File No. S7-28-07
From: Jeffrey C. Keil
Affiliation: Principal, Keil Fiduciary Strategies LLC

January 9, 2008

I applaud the SEC for resurfacing and revising the summary prospectus concept. Clear to most fund business participants is that the typical investor simply does not wade through the legalese contained in most N1-A filings. While the first few pages get read, the rest simply do not and reliance is heavy on financial intermediaries.

In general, I heartily support the following segments of the summary prospectus proposal: 1) content and order mimic the statutory version 2) both summaries cannot be preceded by any other information 3) hardcopy and electronic versions are available and encouraged and 4) full clarity on breakpoint discounts available and the potential for fleeting advisory fee waivers or expense reimbursements.

However, I submit a few suggestions for the SEC's consideration as follows:

1. Require that a fund divulge it's categorization by the nationally recognized third-party fund trackers - this speaks to the "what you propose to do" vs. "what you actually do" question

2. Consider that the generally required format be quite defined to enable easy comparison by fund investors - effectively allowing for customization invariably adds to confusion and lack of comparability

3. Add a performance benchmark volatility measure to the risk/return summary - this would complement the fund's risk measure and provide a solid sense of market tracking

4. Require a bit more disclosure on intermediary compensation - while having a note that says "talk to your broker" is advisable, I believe the investor should know specifically what costs paid at the fund level flow to their advisor

5. Require that a benchmark for the annual operating expenses charged by the fund be disclosed - while fund performance has long been benchmarked, expenses have not and should be as they (can) significantly erode investor returns long-term

6. Clarify the statement "the end of the most recent calendar quarter" - some consistency amongst funds would be useful, i.e., do not allow for fiscal periods (if they are not standard calendar-based) to allow for comparability

7. Ensure that a fund may not use "team" to describe a fund's portfolio managers consider a requirement to identify the "lead manager," if he/she designated

8. Ponder whether a "Derivative Use Summary" may be useful - while admittedly problematic from several angles, a small re-cap that includes a (current) rolling % of assets, purpose(s) of derivative use, and a risk measure of some sort could be enlightening

and last, by certainly not least ...

9. Limit the length of the prospectus summary to x pages - I would guess that 4 pages is a bit too long, while 2-3 might garner more eyeballs

I trust my comments are useful, appreciate the opportunity to comment on this proposal, and look forward to a final Rule in the near future.