From: Wayne McCullough
Sent: March 29, 2005
Subject: File No. S7-06-04

Wayne McCullough
989 Cordova Station
Cordova, TN 38018

Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Jonathan Katz:

To whom it may concern: I have been in the insurance business for over 30 years, and licensed to sell variable products and mutual funds for over 15 years. I am writing to you to object to the additional new disclosure requirements in SEC's proposal regarding mutual funds and variable products. These new requirements would be redundant information. I am already overloaded with paperwork requirements, so I really don't want more to do when the job is already done by the prospectus. I am all for consumer protection. I want my clients to be well-informed about fees and expenses, and sales charges. But, more than they would ever want to know about those things is already in the prospectus. An additional requirement at the time of sale will increase the complexity and confusion, not alleviate it.

For these reasons, I ask that the NASD withdraw the proposed additional requirements. Thank you for your consideration.


Wayne McCullough