Subject: File No. S7-06-04
From: Richard Berwanger

March 16, 2004

I believe regulations in this area is long overdue. While the proposal is fairly good overall, I do not think it goes far enough.

I would especially like to see more information divulged in the hidden costs of mutual fund costs passed on to investors in the buying and selling of shares of common stock for the fund. I believe most funds are paying more than their fair share for these transactions, but do not object because of kickbacks in various forms from the brokerages they do business with.

I also would like to see more included on the relatively rising new trick of having a performance based extra fee if the fund meets certain criteria. Investors should expect their managers to exceed certain benchmarks without having to pay extra for this. It is too much of a one-way street.

It would also be helpful if the portfolio managers, assistants, and top executives of the funds salaries, incentives, and beneficial ownership of fund shares was a mandatory disclosure requirement.