From: Steven M. Singer [retirementsolutions.net@att.net]
Sent: Wednesday, May 05, 2004 6:17 PM
To: rule-comments@sec.gov
Subject: S7-09-04

To Whom It May Concern:

As a Registered Representative who has been in the business since 1986, I wish 
to offer my comments on the above referenced subject.  

12b-1 fees have enabled shareholders to receive ongoing professional services 
which would otherwise not be available to them or would only be available to 
them at additional costs.  These services that I have provided to my clients 
include ongoing reviews of their investments and the necessary fine-tuning 
that is inevitable in the investment field.  In addition, providing, changing 
or correcting account information is a very common task that needs to be done 
for which the client is currently not charged for.  

Should 12b-1 fees be eliminated, I would have to charge clients for the 
smallest of services just as an attorney charges for taking a phone call, 
writing a letter, etc.  I would prefer not to do that.  I also fear that those 
of us who cannot legally charge fees for the service they render, would cease 
to service clients they can no longer be compensated on.  This in turn would 
hurt investors.  Or worse yet, an advisor would feel compelled to sell a 
product to a client in order to make it profitable to the advisor.  

Instead of attacking 12b-1 fees, I would prefer that the SEC look into the 
issue of how much a mutual fund company charges its investors in the form of 
management expenses.  My most trusted and admired mutual fund company, The 
American Funds, charges on average, 1/2 of what the industry as a whole 
charges its investors.  This includes the 12b-1 fee.  The American Funds 
understands the importance of keeping fees to a minimum but it also 
understands that the Registered Representative is asked by is clients to 
perform many ongoing tasks during the life of the relationship.  

Thank you for considering my viewpoint.  I would be happy to answer any 
questions you may have.

Sincerely,

Steven M. Singer
Mutual Service Corporation