From: John Goodwin [jwgood@swcp.com]
Sent: Monday, April 12, 2004 4:19 PM
To: rule-comments@sec.gov
Subject: Mutual Fund Disclosures (s7-06-04)

Jonathan G. Katz, Secy    
US Securities & Exchange Commission   
450 Fifth St NW
Washington, DC 20549-0609

Dear Mr Katz

This letter is in response to the proposed rule changes for disclosure 
to customers purchasing mutual funds.

1.  We would question the need for THREE disclosures of fees to the 
investor before finalizing a mutual fund investment.  One, or maybe two, 
would seem to be sufficient.

2.  The disclosure of conflicts would be simple for a small firm like 
ours, but could prove to be overwhelming for a larger firm--overwhelming 
to both the firm and the customer.

3.  It seems that providing a document on pricing of all aspects might 
be simplest----to include, asset based fees, commissions, and the 
various share classes for funds.  Client could simply sign off that they 
have been informed of the various fee arrangements available and have 
chosen, with their representative, the one best suited for them.

4. In general, we feel that the current environment of strong 
competition between various investment professionals and investment 
firms assures low costs and adequate information to the customer in 
their investment endeavors;  any further intrusion by regulators may not 
be at all helpful to the investor.

We appreciate your review of our comments.

Best regards,


John W. Goodwin
President


David R. Browning
Vice-President

Goodwin Browning & Luna Securities, Inc.
7891 Academy NE
Bldg 2, Suite 101
Albuquerque, NM 87109