Subject: File No. S7-06-04
From: Dan Allen
March 30, 2005
Jonathan G. Katz
Secretary, Securities and Exchange Commission
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
If I were to take a highlighter and highlight all of the cost and expense portion ( or any portion) of a porspectus, that would be considered an unethical , if not an illegal, selling procedure. It has been pounded into us for years. And yet, that is exactly what you are doing by requiring a single page of disclosure seperate and apart from the prospectus. You are "highlighting" certain aspects of investing seperate and apart from the process of "full disclosure". And that is on top of existing forms such as the EOI that are already "highlighting" if you will, seperate and apart from the full disclosure of the pospectus, certain aspects of investing .
The very thing that we have been "beat over the head" for is now being considered a requirement. This is the kind of thing that keeps those of us in the field wondering "Whose on First ????"