Subject: File No. S7-06-04
From: john b williams

January 30, 2004

Mutual funds expense disclosure is inadequate. No one can really understand the lanquage used.
The 12-1b charge in my opinion is one of the worst areas of expense incurred. The fund companies
should be required to describe in DETAIL exactly what this money is used for, even if it requires
a full page in prospectus or other disclosures. Who get what and how much. It would seem that
a fixed ratio of 12-1b expenses taken out of the fund NAV periodically ignores the fact that when
investments within a fund grow from customer investing that the percentage deducted for 12-1b
should logically be reduced on a quarterly or at least annually. Fixed rate of any expense items
ignores the fact that as a fund grows that the cost incurred by the fund is spread over a larger
number of customers investment dollars....a flat percentage that never changes is wrong.