From: bnlem@juno.com Sent: Sunday, January 25, 2004 3:29 PM To: rule-comments@sec.gov Subject: New Confirmation and Point of Sale Disclosure Requirements Brian Lem 727 Herndon Woods Ct. Herndon, VA 20170-5137 bnlem@juno.com (703) 264-4820 January 25, 2004 Dear Mr. Katz: I have read several articles in The Washington Post that address the SEC's proposals to improve disclosure requirements to mutual fund investors. I would like to recommend that the SEC mandate a "truth in investing" model similar to the Truth in Lending provisions that apply to consumer and installment loans. Under the truth in investing model, all mutual fund companies must disclose the gross one-, three- and five-year average return on investiments, as well as those returns after subtracting all applicable fees. A separate section will disclose all relevant fees and their nuances, such as front-load or rear-load sales commission, the 12-1b marketing fees, and the average administrative expenses. These pieces of information will allow investors to make informed choices. Lastly, I also recommend that the mutual funds disclose any potential conflicts of interest amongst its Board of Directors. While the conflicts may not violate any regulations, the disclosures will allow investors to make their own decisions, rather than learning about these conflicts after a controversy has occurred. Sincerely, Brian Lem