Subject: File No. S7-06-04
From: Leonard Viscito, JD
Affiliation: Register Rep.

April 7, 2005

It is unfortunate that the disclosure of information on conflicts of interests, costs and other issues have to be rushed.

These are very complicated issues and presenting them to prospective investors in the wrong format has the potential to make the investor run scared rather than to evaluate carefully.

If President Bush and Congress are attempting to have the investing community understand the benefits of longevity insurance, privately paid for by the investor, the last thing the rules should be doing is discouraging the same investments due to lack of understanding.

Please consider extending the timetable for new rules in order to place the ability of the disclosure requirements to be informative rather than a discouraging factor.

Perhaps behavior experts should be consulted on the appropriate manner and timing of disclosure before rules are finalized.

Len Viscito