Subject: File No. S7-06-04
From: Susan Crabtree

April 6, 2004

Requiring brokers to disclose up-front charges for certain classes of mutual funds is an excellent first move - they should also be required to disclose charges for all classes for which the investor may be eligible. For example, many funds have classes with a front load, but management fees may be lower for this class than for other classes. Charges and actual cost paid should be disclosed for all of the classes, based on the holding periods.

Also, the funds should be required to explain their use of the 12b-1 fees that investors pay for some no-load funds. It is my understanding that 12b-1 fees are supposed to be for advertising and marketing expenses that should theoretically enhance the investor base and lower fees in the long run by spreading the expenses among a larger pool of investors. Yet there are MANY funds that charge 12b-1 fees for which I have rarely, if ever, seen an advertisement or even heard of. Average trading costs should also be disclosed as much as possible.