Subject: File No. S7-28-07
From: Daryle L. Owen

August 2, 2008

This is on the proposed mutual fund prospectus. Under subject i have trid to put an s but it looks like a five. Now for my comment. I do not believe a prospectus should say exchanging one fund for another. There is nothing exchanged here one fund is bought and the other is sold. If this was not in there a broker could not tell a client who does not read or understand the prospectus he will exchange funds for them.. Daryle L. Owen