Subject: File No. S7-09-04
From: Robert O Troxell

May 6, 2004

1. Rule 12b-1 has allowed shareholders to receive ongoing professional services.

2. Recission of Rule 12b-1 would increase incentives to churn.

3. Rule 12b-1 aligns shareholder and broker interests.

The receipt by broker/dealers and their representatives of 12b-1 fees has enabled shareholders to receive ongoing professional services, which would not otherwise be available to them or only available at additional costs. These services include not only administrative services, such as providing, changing or correcting account information, but also substantive assistance through the provision of analysis and financial planning for these shareholders.

Thank you for concidering these points.

Robert O. Troxell