Subject: File No. S7-06-04
From: John Poff W Poff, Mr.

April 1, 2005

Gentlemen and Ladies,

As President of Mutual Service Corporation, I represent approximately 1,800 registered representatives who are associated with our firm. Our initial study of proposed Rule S7-04-06 leads us to believe that the firm, our representatives, and their clients will be negatively impacted if this rule passes without significant changes as a result of the horrendous cost that the rule will add to firms that provide a wide variety of products to the investing public. We fully support the Commissions goals of full and fair disclosure, but need additional time to further study the rule and comment constructively with suggested changes that might work to mitigate unintended consequences of the proposed rule. We therefore, respectively request that the Commission extend the deadline for comment on Rule S7-04-06 for a minimum of thirty calendar days until May 4, 2005.


John Poff
Mutual Service Corporation