Subject: File No. S7-06-04
From: Ronald D Rubach

March 16, 2004

It is gratifying to see this substantive attempt at providing needed disclosure for us in our selection of the vast array of fund choices. Each item proposed is accutely necessary in making comparisons. I believe the list is presently complete but should also provide that any future or further items must be specifically detailed.
Perhaps it is not necessary to include any explanation of items which do not apply. This would shorten the disclosure and tend to make it easier to digest. If the applicable items could be collected at the beginning of the form, it would also enhance comprehension.

Do not allow the point-of-sale disclosure be done in oral fashion. It is too extensive and not readily comprehended in other than written format.

I appreciate the opportunity to comment. As the former director of enforcement for the State of Michigans Securities Bureau for over 10 years, I interviewed many individual investors trying to understand the varied investment products. This will definitely help if passed.