Subject: File No. S7-06-04
From: Andrew Bairnsfather

December 16, 2004

Secretary Jonathan Katz

Dear Secretary Katz,

As an investor advocate, I commend the Commission for its bold step to require brokers to provide pre-sale disclosure of costs and conflicts of interest when they sell mutual funds. However, I am concerned that certain aspects of the proposal, including the proposed timing, content, and format of the disclosures, need improvement.

With a few strengthening provisions, others believe this rule proposal could help investors to make more cost conscious mutual fund purchase decisions, potentially saving us tens of thousands of dollars over the life of our investments.

Specifically, the rule should provide for written disclosures at point of recommendation, rather than point of sale. The disclosure rule should also include mutual fund operation costs, including sales-related costs. Finally, disclosures need to be provided in a clear and simple manner so investors can understand them.

There is gross conflict of intersted in many aspects of our government and society, please help us little people from being preyed on even more. I trust CU enough to go along with this letter. Thanks for considering my concerns.


Mr. Andrew Bairnsfather