From: Doug Clelan (Clelan & Company) [dougc@clelan.com]
Sent: Monday, May 03, 2004 3:48 PM
To: rule-comments@sec.gov
Subject: 12(b) 1 fees (s7-09-04)

Thank you for the opportunity to comment on the discussion about the repeal or 
restriction of 12(b)1 fees.  I applaud the SEC for looking into abuses in the 
mutual fund industry.  However there is a tendency to over react to information 
uncovered in any investigative process.  The 12(b)1 fees paid to registered reps 
for on going service are quite nominal and, in most cases, represent the only on 
going compensation to the RR.  Without 12(b)1 fees service to the consumer will 
suffer and other revenue sources will have to be found.  When this occurs  the 
consumer generally pays.  The focus ought to be on providing better, more 
understandable disclosure and the abuses that line the pockets of fund 
executives at the consumer's expense.

-- 

Douglas R. Clelan
****************

Douglas R. Clelan, CLU, ChFC

Clelan and Company 

…. Optimizing Your Success 

210 Grandview Avenue, Suite #101……………...…Telephone (717) 761-4633 
Camp Hill, PA 17011…………………………........…Facsimile (717) 761-1331  
Securities offered through Walnut Street Securities, Inc. Member NASD, SIPC, 270 
Walker Drive, State College, PA 16801 (814) 238-0544. Advisory Services through 
PFG Financial Advisors.