Subject: File No. S7-06-04
From: Stephen W Howells

April 3, 2004

-The word mutual implies a co-ownership of the fund with management. As such, there is no possible reason for withholding any information from the investor.
Trouble is that complete disclosure would result in a long and tiresome format, which would not be read anyway.
My solution to this would be a knowledgeable panel of experts to provide this disclosure in a simple bullet format. The participants could be a small less than 6 group of professionals from companies that serve the general public like Morningstar and Hulburt. To withhold information from this panel would be tantamount to admitting chicanery.
This solution needs a great deal of fine tuning. But, if approached from a sincere desire to perform disclosure, it has a chance.
This proposal is only a starting point. I dont have all the answers, hopefully a few.