Subject: File No. S7-06-04
From: James A Cox, III
Affiliation: Registered Rep, Mutual Service Corporation

April 1, 2005

The provisions of this proposal will be extraordinarily burdensome to brokers/dealer in terms of cost. I think that the SEC should divert its time and energy to prosecuting variable annuities and those who sell them. I ask why you would devote so much time to non-essential, worthless endeavours, when you could make a difference by putting a stop to the fleecing of the american public by insurers and those incented to sell their products. You have beaten down the mutual fund industry on cost; however, to date, you have done nothing to stop the most expensive financial product ever produced.

I would appreciate the opportunity to discuss this matter at length. 804 518-1525