Subject: File No. S7-10-97
Date:    06/06/1997 7:01 PM
     
     
     BankBoston Investor Services, Inc.
     100 Federal Street
     Boston, MA  02110
     
     
                                                June 6, 1997
     
     
     
     Mr. Jonathan G. Katz, Secretary
     Securities and Exchange Commission
     450 5th Street, NW
     Washington, DC  20549-6009
     
     Re:        Registration Form Used by Open-End Management Investment
                Companies, File No. S7-10-97
     
     Dear Mr. Katz:
     
        BankBoston Investor Services, Inc. appreciates this opportunity to
     comment on the proposed amendments to Form N-1A set forth in Release 
     No. 33-7398 (Feb. 27, 1997).  BankBoston Investor Services, Inc. is a 
     registered broker/dealer and is a wholly-owned subsidiary of 
     BankBoston, N.A., a national bank that, together with its affiliates, 
     has approximately $65 billion of assets as of March 31, 1997. 
     BankBoston, N.A. serves as investment adviser to Boston 1784 Funds, a 
     registered open-end management investment company, and sales of Boston 
     1784 Funds make up an important part of BankBoston Investor Services, 
     Inc.'s business.
     
        Proposed Item 2(c)(1)(iv) provides that, if the Fund is not a Money
     Market Fund but is advised by or sold through a bank, the risk/return 
     summary must state that "An investment in the Fund is not insured or 
     guaranteed by the Federal Deposit Insurance Corporation or any other 
     government agency."
     
        We believe that the risks of customer confusion are just as great
     for customers of nonbank broker/dealers as for customers of bank 
     broker/dealers, and that similar measures to combat customer confusion 
     are appropriate.  A recent survey of mutual fund shareholders conducted 
     by the Securities and Exchange Commission and the Office of the 
     Comptroller of the Currency shows that customer confusion extends across 
     all distribution channels, including the broker/dealer distribution 
     channel.  Mutual Fund Shareholders:  Characteristics, Investor 
     Knowledge, and Sources of Information (June 24, 1996).  Of investors who 
     bought mutual fund shares, 13.3% who purchased through the bank 
     distribution channel and 12.3% of all investors believed that investors 
     cannot lose money in a bond fund, while 20.1% of bank channel investors 
     and 20.5% of all investors believed that investors cannot lose money in 
     a money market fund.  Id. table 15A.  The same study found that 36.4% of 
     bank channel investors and 33.1% of all investors believed that money 
     market funds are insured.  Id. table 34A.  The differences between bank 
     channel investors and all investors were not statistically significant.
     
        Since investor misunderstandings are substantially the same across
     all channels, we believe that efforts to address those 
     misunderstandings should also be the same across all channels. 
     Accordingly, we believe that Item 2(c)(1)(iv) should apply to every 
     Fund that is not a Money Market Fund, not just Funds that are advised 
     by or sold through a bank.  Requiring this disclosure for some Funds 
     but not for others may aggravate the problem by leading 
     unsophisticated investors who compare prospectuses to believe that 
     Funds without the disclosure are insured.
     
        We appreciate the opportunity to comment on this important issue.
     If you would like to discuss these comments further, please do not 
     hesitate to call me at 617/434-9471, or John Baker of our Law Office 
     at 617/434-8796.
     
                                                Very truly yours,
     
     
     
                                                Richard E. Horn
                                                Vice President