From: Manny Um
Sent: March 30, 2005
Subject: File No. S7-06-04

Manny Um
333 Sylvan Ave, Suite 303
Englewood Cliffs, NJ 0763

Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Jonathan Katz:

It is too much complicate for prospects and clients.

I am a licensed insurance professional and variable products salesperson.

I am writing to you because the new disclosure requirements contained in the SEC's proposal regarding the sale of mutual funds and variable products are unnecessary and will provide no meaningful additional protection to consumers.

Mutual fund and variable annuity prospectuses, which are reviewed by the SEC, already discuss the fees, risks and expenses associated with the purchase of these products. Very recently, in 2002, the SEC took steps to simplify the contents of the prospectus.

For these reasons, I urge the NASD withdraw the proposed rule.

Thank you for your consideration of my views on this matter.


Manny S. Um, CLU, ChFC