From: Pastella, William P [PVTC] [william.p.pastella@smithbarney.com]
Sent: Friday, December 26, 2003 8:48 AM
To: 'rule-comments@sec.gov'
Subject: (s7-29-03) FW: Mutual Fund Transaction Costs Disclosure




> Thank you for this opportunity to comment. Mutual fund transaction costs
> should be disclosed alongside the management fee on the "annual operating
> expenses" page of the prospectus, as well as included in any piece of
> literature approved for distribution without a prospectus. My experience
> is that most financial advisors fail to disclose there costs, either
> through lack of awareness or a purposeful omission to enhance their
> probability of making a sale. The same is true in the case of variable
> annuity products' fund accounts. Granted, the costs would be different
> each year, but perhaps a table such as: 
> 
> If the portfolio turnover is XXX% the transaction cost would be X.XX%.
> "       "         "      " 	        YYY%
> Y.YY%
> etc.
> 
> Right next to this table would be the actual portfolio turnover
> percentages (historically) for the particular fund.
> There should also be a simple explanation of how portfolio turnover is
> calculated.
> 
> Thank you and good luck.
> 
> William P. Pastella, CIMC
> First Vice President - Investments
> Senior Investment Management Specialist
> William.P.Pastella@Smithbarney.com
> 

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