From: Byrne, Beverly A [beverly.byrne@gwl.com]
Sent: Wednesday, July 31, 2002 4:59 PM
To: 'rule-comments@sec.gov.'
Subject: File No. S7-17-02

Comments on Rule: S7-17-02 "Proposed Amendments to Investment Company
Advertising Rules" 
Ladies and Gentlemen:
BenefitsCorp Equities, Inc. ("BCE") applauds the proposal to require fund
companies to promptly provide performance data.  We are a broker/dealer
marketing primarily to qualified retirement plans  with sales of variable
insurance products as well.  Each retirement plan may have a number of
mutual fund investment options and each variable insurance product may also
have a number of underlying funds.  In order to provide performance data to
each plan and the plan participants and to each variable contract owner, if
even one mutual fund company fails to provide data in a timely manner then
the broker/dealer cannot, in turn, provide this information to its
customers.
BCE is interested in the Commission's view concerning the timing of the
broker/dealer's publication of performance data once the fund company has
provided its data to the broker/dealer.  For example, if the fund company
provides performance data on Day 3, the broker/dealer must format the data
and may also need to perform additional calculations to account for any
recurring fees as may be the case for a variable contract that has a
mortality and expense risk fee.  In order to meet the requirements to
include the recurring fees, the broker/dealer will need some reasonable
amount of time to perform such calculations and subject them to a quality
assurance review prior to releasing the performance data.  
Thank you for your consideration of this matter
Sincerely,
BenefitsCorp Equities, Inc.