Subject: File No. S7-06-04
From: James F Hurley, Ph.D.

March 15, 2004

The proposed disclosures and the forms to implement it are most welcome. The contrast between the information provided to purchasers of funds from brokers at present and that afforded by the proposed forms is stunning.

From years of investing in mutual funds, one gradually acquires knowledge about most if not all the points covered, but few if any novice investors are sufficiently well informed to evaluate the broker input they receive and then make optimal decisions. The disclosure required in this proposed regulation goes to the heart of that serious matter.

For maximum value, the information about break points, fees, etc. should be provided prior to purchase, as part of the sales literature brokers give to clients. While the investment records should also show the information for the clients to keep in their permanent records, providing it only at that point might mainly just add to their regret after the fact of having made unwise investments, instead of helping them avoid such poor choices in the first place.