Subject: File No. S7-06-04
From: Bernard L. Minetti

February 18, 2004

I believe the forms are very good but do not go far enough. There should be a grace period of maybe three business days built in to each purchase in order to allow for cancellation should a purchaser be unhappy with the fee structure or not be happy with the investment move.

There is also no discussion of special penalties that are applied to certain funds. For instance, Gabelli Global Convertible Fund, GAGCX, has a 2 percent penalty built in should you sell the fund in less that sixty days. How in Gods name do you protect your principal from adverse management techniques or a declining market without suffering an additional 2 percent added to the loss resulting from the declining NAV. This is a patently unfair proviso and should be barred by federal statute in order to protect the small investor from the unfair rules made by these scoundrel fund managers.

The SEC seems to forget that fund managers make money off our backs whether their funds make money or lose money. The percentage fund fees are always charged. We, the investors lose twice... due to a declining NAV and a voraciously money hungry fund company.

I would like to see a lot more legislation to protect investors since investing governs our personal futures. The companies use the term caveat emptor and hide behind that for their poor management techniques and lay it at the investors doorstep. They need to be made to lose money when the investor loses money. Then there would be a real motivation to work for the success of the investor.

While I applaud the direction that the SEC is taking regarding mutual fund oversight, these forms are merely one small step in the right direction. Please listen to the investor. The Fund companies are only worried about their bottom line, not the investors bottom line. Somehow the system has to be changed so that fund managers work for the fund purchasers and not sole for their own financial well being.