From: George A. Cohlmia [george.cohlmia@wachoviasec.com]
Sent: December 23, 2003
To: rule-comments@sec.gov
Subject: File No. S7-12-03


It is my belief that mutual funds should include transaction costs without opportunity costs. Transaction costs are easy to quantify, with no room for interpretation. Opportunity costs, however, can be debatable.

It is also my opinion that turnover rate should be more freely communicated. In addition, there needs to be some effort put forth to educate the public about what turnover rate means in large cap issues versus small cap issues or international issues. Additional education should include bid/ask spreads and liquidity issues related to different types of securities, both fixed income and equity.

The idea of using soft dollars for research is exaggerated. Most fund compaines have plenty of opportunities to receive research and much of it can be accessed at little or no cost.

The overall goal of your effort should be to place mutual funds on a level playing field with similar investment choices. The clearest comparison would be with separate accounts, wherein wrap-fees generally include most of what is needed.

George Cohlmia
Sr. Vice President - Investments
Sr. Investment Management Consultant
Wachovia Securities