Subject: File No. S7-06-04
From: Irwin Kaplan

March 15, 2004

With regard to mutual fund transparency, it would be helpful for an investor to know as much about a funds portfolio, including, the number of stocks in the portfolio how many are above cost, and how many are below cost.

With this information the investor can make better judgements
on portfolio managment, and quantify past management and the future attractiveness of the total portfolio.

When I requested this information from a fund I owned, I was told this information was unavailable to mutual fund shareholders because it gave infromation to competitors.

Thi is an irrational argument. All information about the portfolio should be made available to shareholders and potential shareholders so that they can make inteligent investment decisions.

A disclosure provision for this type of information should be a legal fund reporting requirement.