Subject: File No. S7-06-04
From: Edward W. Greninger

June 20, 2004

Prospectus should provide an explanation for all expenses associated with purchasing holding or selling a fund. These should include: costs of trading, including compensation to larger distrubutors of the fund such as Schwab, Fidelity, Vanguard, etc., how many shares of the fund the broker or fund manager personally holds, the internal rate of return of the fund over 1,3,and 5 years.

Otherwise your proposals are good and should be adopted.