Subject: File No. S7-06-04
From: Michael Standley

February 16, 2004

I agree with full fee disclosure from every angle of this business. In that light, I feel that the so called no load funds disclose all of their Cost-to-own that might include advertising and soft money paid to those who recommend their products. There are no such things as No cost funds. If the fund pays the broker-dealer to sell their product, or pays Money magazine for full page ads, the cost is always born by the consumer.
Like any industry in this country, there are opportunist that stretch the rules. They need to be stopped for the benefit of all involved. What we dont need is a blanket change of industry regulations that only effect commission based brokers and advisors because of an idea that,if you make money by selling a product, you are always at fault for selling it.