Subject: File No. S7-06-04
From: Geoffrey L London

March 1, 2004

gentlemen: Please do not go too far with this mutual fund reform. What I have seen so far is too much.
First, I am opposed to revokable transactions. Can a consumer return a suit or a car or a house if he decides he doesnt want it several days later? Is that fair to the agent or the seller? Adequate disclosure ahead of time should preclude that.
Second, it would be such an enormous mistake to eliminate 12B-1 fees. If your goal is to see that mutual fund owners get no ongoing service from their financial representatives, then go ahead and get rid of the 12B-1 fees. That way the representative will be faced with either convincing the investor to buy another fund generate another commission or he will just go looking for new clients. You see, the 12B-1 fee ties the agent to the investment. Go ahead and disclose it, but do not, under any circumstance, eliminate it.
Also, we need another 120 days to review this 100 pages of stuff.
Thank you.
Geoff London, after 32 years in this industry