Subject: File No. S7-06-04
From: Edward J. HELDMAN

March 15, 2004

1. Conflicts of Interest is a major concern. Mutual funds should be required to disclose any potential conflicts of interest, as defined by the SEC.
2. Profile of funds shareholders. A mutual fund should be required to disclose, statistically, the make-up of the funds shareholders, that is the percent of shareholder holdings by individual investors, institutional investors, business entities, pension plans, etc. That may help enable the small investor to decide if the funds management strategies are consistent with their investment goals.
3. More discolsure is needed of a funds administrative and executive costs, such as mangers compensation and fund family assessments, so that an investor can make a more critical assessment of whether their investment is being managed at a reasonable return-on-expense. Are we getting the quality of fund management we are paying for?