Subject: File No. S7-06-04
From: William C. Alsover Affiliation: Centennial Securities Company

April 1, 2005

Fees and expenses are an important part of the selection process, but not the only part. These proposals focus entirely on the costs, with no guidance or disclosure regarding the risks and returns associated with mutual funds.

The costs to all firms, particularly small firms, will be extremely high, and likely will cause a reduction in the selection of funds offered. Less selection to investors is not the intent of these rules, but I believe it will be one of the outcomes.


William C. Alsover
Centennial Securities Company
Centennial Securities Company, LLC
Main Office
3075 Charlevoix Drive, SE
Grand Rapids, MI 49546
(616) 942-7680

from: Bill Alsover
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