From: Jack Vandy Bogurt [jlfinancial@sbcglobal.net]
Sent: Thursday, April 29, 2004 3:30 PM
To: rule-comments@sec.gov
Subject: File No. S7-09-04

I strongly urge the SEC to reject any proposal to eliminate the 12B-1 fees and
the ability to pay 12B-1 fees to registered representatives.  

As a licensed insurance agent and a registered representative I, of course, have
a vested interest in knowing how I will be paid for the service I provide.  12B-
1 fees, like a renewal on insurance products, keeps me interested in the
client/customer and is a reasonable cost to them.  I fully disclose these fees
with every purchase and have never received complaints for this small amount
they are charged.      

As a financial professional I have grave concerns that eliminating service fees
will leave the Middle America investor at the mercy of every Customer Service
Representative.  It seems improbable that a CSR has depth of knowledge across
multiple product lines and it is sure that they do not know the
client/customer's goals, desires, and family situation as I do. If anything, I
believe that 12B-1 fees assists in "KNOWING YOUR CLIENT/CUSTOMER", as providing
ongoing service, at least in this office, means updating Customer Account
Records and making sure investments continue to match goals.

I also have grave concerns that changes being proposed are seen as an easy,
public fix to a part of the mutual fund industry that isn't broken.  The results
of those changes will be to provide less service and counsel to the very
citizens we are trying to help as  regulators or registered representatives.

For the above reasons, I again urge the SEC to reject any proposal to eliminate
or restrict the ability of mutual funds to pay 12B-1 fees to registered
representatives for providing continued service to their clients.

Thank you for consideration of my views.

Jack L. Vandy Bogurt
615 North Drive W.
Marshall, MI 49068