Subject: File No. S7-03-04
From: Richard F Curcio
Affiliation: Chairman, The Valiant Fund

July 27, 2006

To whom it may concern:

As Chairman of The Valiant Fund, an institutional money market fund that I started in 1993 by investing more than $1million of my own money to fund its start up, I find the proposed new rules an unnecessary expense that will not serve to protect shareholders. In the case of The Valiant Fund, which is an institutional money market fund with a management fee that is capped at 20 basis points, the proposed rules will do nothing but add approximately $100,000 in costs that I as the advisor will have to pay. Since our management fee is capped, these costs cannot be passed on to shareholders. The current makeup of our Board is four independent trustees and two interested trustees, one of whom, myself, is the Chairman. If the two interested trustees remain, we would be required to recruit and hire two additional independent trustees as well as appoint an independent Chairman.

Our clients are fully aware of our fund and literally vote with their feet on a daily basis if we fail to perform or act in other than their best interests. How having an independent Chairman who may be unfamiliar with the daily operation of our fund will better protect shareholders is beyond my comprehension. This rule will do nothing more than force small independent funds, like The Valiant Fund to merge with other large mutual fund companies. It is also interesting to note that the recent mutual fund problems were with large organizations some of which had independent Chairman.

I would urge the Commission in the interest of fairness and real protection for shareholders to not implement the proposed rules.


Richard F. Curcio
The Valiant Fund