Subject: File No. S7-06-04
From: David J McBride, CPA, CFP

March 1, 2004

The proposal to revoke 12b-1 fees in their entirety would not be in the clients best interest.
The nominal trail commission that is paid to continue providing answers and service to clients
after the initial investment is necessary. If the fee is revoked, you will see smaller accounts
ignored, passed off to others, and/or the accounts will be traded to generate new commissions
to compensate for ongoing advice. Compensation needs to exist to service ongoing client
needs and concerns. Smaller accounts will not pay an hourly charge and may not be suitable
on a fee basis.
Your reconsideration of this issue is appreciated.