From: Jerome Pfeffer
Sent: March 31, 2005
To: rule-comments@sec.gov
Subject: File No. S7-06-04

Dear Sirs;

In regards to The Proposing Release, release #33-8358 and 34-49148 the proposed rule will create unintended consequences for the investor. Fund investor’s will ultimately pay the Fund’s cost to prepare and update prospectuses and point of sale disclosure documents. And for independent broker-dealers, the cost associated with this process will have the unintended consequences of prohibiting these broker-dealers from continuing to offer investors a broad selection of “covered securities.”

Jerome Pfeffer
Investment Solutions
Wealth Management Group
6020 Academy NE, Suite 202
Albuquerque, NM 87109
505-856-9249

Managing the growth & preservation of wealth.