From: Michael K Reynolds [Michael_K_Reynolds@mony.com]
Sent: Thursday, April 22, 2004 10:11 AM
To: rule-comments@sec.gov
Subject: FILE NO. S7-11-04.......REDEMPTION FEES

   in regards to the proposed 2% redemption fee applied to mutual funds, i am 
adament about the fact that this is something which must be applied as soon as 
possible. in fact i would be supportive of an even higher fee of maybe 3%-4%. 
the operating cost of mutual funds clearly spikes upward, and hurts the 
average long term investor, as a result of a select few which manipulate the 
proper investment objective of the mutual fund product. 

   i also would like to see the holding period much longer than five days. i 
believe that a holding period of at least a month is required, and i can't 
even see the need to sell a mutual fund after just a month either. a five day 
mandatory holding period still allows institutional investors with superior 
analytical software to be able to market time. the holding period MUST be 
longer. the only exception would be an unanticipated financial emergency. one 
which is more stringent than the one used to give exceptions for early 
withdrawal on IRA accounts. circumstances such as death, disability or a 
sudden economic hardship. NOT situations such as home ownerships down payments 
or college tuition, since these are not sudden instances. 

   the redemption fee should work on a FIFO method, which seems to be the 
normal method for determining other charges such as taxes. i also don't feel 
there should be a de minimis exception. 2% is 2%, so a small investor would 
only get hit with a small charge, and small investors are rarely the ones who 
market time anyhow. 

   finally, the only way to make this work would be to make this a blanket 
rule. no funds would be exempt, and it would have to be the same percentage. 
funds would have to institute this charge on ALL investors. without making it 
mandatory, some funds would not charge the fee, thereby taking business away 
from funds that do charge the fee. it is important that whatever is done, the 
most important thing is consistency. all funds must follow it equally, and to 
the law. anything else would make the process unbalanced, and give investors 
yet another reason to be wary of those who are supposed to be managing their 
money efficiently. 


i would be happy to go into detail, or to touch on other points if need be. i 
just thought i'd comment on the first things that came to mind. please let me 
know how else i can contribute. thank you. 


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