Subject: File No. S7-06-04
From: Roark Young
Affiliation: President, Young, Stovall and Company

April 2, 2005

I believe it is extremely important to provide full disclosure to the investing public, however isnt this already provided in the prospectus the client receives when they purchase a mutual fund or 529 plan? By placing additional burdens on the investment professional, I am concerned that we will open up additional claims as to liability on technical merits only. This serves no one. Investors should have some responsibility for making investment decisions. I agee that the investor should be provided with proper information and be informed and educated before making an investment decision, but additional burdens on the investment professional will not provide this. An investor is already provided with full disclosure in the form of a prospectus. A plethora of information is available to everyone from either the mutual fund, the brokerage firm, or hundreds of websites. Investor who are wronged are able seek relief in arbitration or court proceedings. Brokers who take advantage of the public are being dealt with by the regulators or various SRO committees. Our role as industry leaders should be to educate the investing public, not just at the time of a sale but as a life long commitment, then when a purchase of a security is made we can all rest assured that the customer understood what they invested in and why. These disclosure rules do not do this, they simply provide additional fuel to an already over zealous litigation environment.