June 30, 2000

Jonathan G. Katz
Securities and Exchange Commission
450 5th Street, NW
Washington, DC 20549-0609

Re: Comments to Proposed Disclosure of Mutual Fund After-Tax Returns
File No. S7-09-00

Dear Mr. Katz:

Fortis Financial Group appreciates the opportunity to comment on the Securities and Exchange Commission's proposed rule on mutual fund after tax disclosure.

Fortis supports the recommendations submitted to the SEC today by the Investment Company Institute. While we have some reservation over the meaningfulness and clarity of the proposed after-tax disclosure to the individual investor, we are in support of the SEC's overall objective, namely, to improve after-tax disclosure to investors. We feel that the ICI's recommendations provide clarity to the original proposal and we ask that you consider and ultimately adopt their modifications in any final rule.

Thank you for your consideration.

Yours sincerely,

Richard J. Ertel
Legal Resources & Compliance
Fortis Advisers, Inc.