From: Bob Richards [richards@pixi.com]
Sent: Thursday, January 22, 2004 11:33 PM
To: rulecomments@sec.gov
Subject: New Confirmation and Point of Sale Disclosure Requirements

Aloha,

I understand the SEC has proposed new investment company guidelines 
for mutual fund companies and the sale of fund shares.  I fully 
support the following proposed rule changes:

  a.. Investment advisers for mutual funds would have to adopt codes 
  of ethics that address, among other things, personal trading by 
  employees who have access to nonpublic information. 
  b.. Seventy-five percent of the board of directors for a mutual 
  fund company would have to be independent. And the board would have 
  to be led by an independent chairman. The SEC said this requirement 
  would strengthen the presence of independent directors and improve 
  their ability to negotiate lower advisory fees and other important 
  matters on behalf of the fund and fund shareholders. 
  c.. Professionals who sell mutual funds would have to reveal the 
  costs of buying fund shares and any possible conflicts of interest. 
  And the transaction cost must be expressed in dollars and as a 
  percentage of the net amount invested. In addition, any dealer 
  concession that the broker, dealer or municipal securities dealer 
  (folks selling 529 plans) earns in connection with a transaction 
  must be expressed in dollars and as a percentage of the net amount 
  invested. 
  d.. Customers would receive cost and conflict of interest information 
  at two key times - first at the point of sale, and second at the 
  completion of the sale. 
  e.. Companies would have to give investors information that would 
  help them see how their particular mutual fund's costs and payments 
  compare with those of other similar mutual funds. 
As a small investor I appreciate this opportunity to weigh in on 
these issues.

Hau`ole Makahiki Hou,
    (Happy New Year)
        Bob
Robert D.V. Richards, Jr.
94-205 Makawai Place
Waipahu, HI  96797-5635