From: BRAD.SKILES [brad.skiles@kconline.com] Sent: Thursday, April 29, 2004 9:04 PM To: rule-comments@sec.gov Subject: File NO. S7-09-2004 Dear Mr. Jonathan G. Katz, Secretary/Securities and Exchange Commission I am a licensed insurance professional, registered representative, and registered investment advisor representative. I appreciate the work the SEC is doing to eliminate unlawful conduct in the mutual fund industry. Many changes were needed and are being pursued. I’m writing to express concern about the consideration for a complete elimination of 12b-1 fees. I would estimate that 80% of my clients with mutual funds expect me to service their changing needs. My client base is not looking to me for a one-time transaction; nor do I look to them for simply a product sale. If there was a single compensation for a mutual fund, there would be no way to be compensated for years of future service … other than to try to make new sales—which would be a terrible business plan. The block of business I have pays me a minimal trail fee which helps me justify the annual reviews I do with my clients. For the client with an “A” share, the annual “12b-1 fee” on a $10,000 investment would cost him or her about $25 per year. From that $25, I receive about $15. For my business, that adds up to about $18,000 which helps provide the income for this type of service. When I sell a mutual fund, my promise to the client is to meet at least annually to review the funds and their objectives. A one-time sales commission would not permit me to do that … year-after-year. If my client wanted to simply buy a mutual fund as a commodity--without any future advice or service--they could do that through a no-load company. I urge the SEC to reject the idea to eliminate 12b-1 fees. Eliminating this service fee would hurt the consumer whom you are trying to protect. Thank you for considering this. Brad Skiles Woolman Financial Group 119 E. Center St. Suite B-3 Warsaw, IN 46580 Phone 574-269-6592 Registered Representative and Investment Advisor Representative, Securian Financial Services, Inc., Securities Dealer, Member NASD/SIPC A Registered Investment Advisor 3230 Central Park West, Suite 100 Toledo, OH 43617 (419) 843-4737