Subject: File No. S7-06-04
From: Edward T Duffy

March 22, 2004

I believe the revised forms proposed by the SEC are helpful to individuals such as me who manage most of their financial assets personally, tend to work with discount brokers and who generally utilize mutual funds or ETFs as the investment vehicle of choice for a bulk of the financial assets.

An area I would like to see addressed more directly relates to commissions and embedded soft money transfers from the fund to a broker via above market commission payments for benefits such as Research and office equipment such as computer and related hardware/software.

Commissions should be identified as a separate line item in all fund reports, not just transaction statements.

Also, it would be most useful if there were some indication of that percentage of the commission went for soft money items.

While one might argue that such a measure is subjective, it certainly could be estimated using some standard approach. What should be obvious to all concerned is subjectivity is no excuse for not providing estimates. So much that is used in the financial world is subjective. One tires of the firms who utilize subjective techniques to provide data when it advances their cause but reject subjective techniques when those technigues might or could reveal that a firm fund, broker, company does not perform as well as some of its competitors/peers.

Thank you for the opportunity to voice my views.