Subject: File No. S7-06-04
From: Emmett Rogers

March 16, 2004

I support any effort to maintain and improve true fiduciary disclosure and handling of BOTH mutual fund and annuity contracts and performance for benefit of the individual investor. I had a particularly poor experience with a sec. 1035 transfer of an annuity. The transferring entity took their sweet time finding all sorts of reason to delay. Apparently there are no deadlines for such handling except for the purchaser. In my experience red tape delays may be the norm. The markets were going against me and no change in the allocations was possible pending the transfer. The transferee received the fund transfer by mail and took their sweet time in investing the funds as the market finally turned thus I wound up with a hit by reason of low sales and a high purchase. In my view, there is little if any reason for there not to be regulations specifying same day sale and repurchase in this age of instant electronic fund transfers, It is important to know such potential costs as well as actual costs to be expected and about any conflicts of interest that are built in.