Subject: File No. S7-06-04
From: C. Robert Kelly
Affiliation: ChFC, MEd

April 1, 2005

It would be nice if I knew what the file S7-05-04 contained.
Never having seen it or even heard of it before today, I would like you to afford us affected by it some more time to consider its implications.
I am all in favor of full and copmplete disclosure pertaining to investments. I dealing with qualified plan clients, 95+ of my business, I attempt to disclose both the stated costs and as best as I can the under disclosed expenses. I am also extra careful to reveal my compensation from the program.
But pure reporting will not solve every problem. I sales process has to be carried out by ethical individuals. Thankfully for my clients, I and my associates work very hard to act solely in the interest of these individuals