Subject: File No. S7-06-04
From: Nancy S Walls, CFP

April 6, 2005

While I am much in favor of disclosing fees to clients, the changes being proposed need to be very carefully thought out as to the impact on not only the client but also the professionals in transacting investment business for those clients.

Weve seen the impact of not thinking through all consequences of change with the recent change of broker/dealers no action letters. This change was so negatively impacting business for both the broker/dealer and the client, that the change was recinded.

Lets just be sure weve thought this through thoroughly before we make such drastic changes.