Subject: File No. S7-11-04
From: Darrell D. Wiard

May 20, 2004

A market commentator who I read had an interesting comment today about the potential for the market to resume its bullinsh recent trend, or continue to sink as it has been since early March. The quote is as follows:
With so much gunpowder on both sides -- more gunpowder than ever before in more complicated, more sophisticated, more educated and more leveraged hands with so many hedge fund and mock-hedge fund strategies being deployed -- whatever direction we ultimately go in, its likely to go much further, much faster than anyone expects.

The ultimate effects of Iraq, India, China, currency, oil, inflation, interest rate creep, liquidity-pumping, etc. are far harder to game than the day-to-day movements based off the incremental news flow on each issue.

I mention this quote to emphasize again the extremely volatile nature of the marketplace today. In even five days, an investor locked into a position can sustain a significant loss. I know that at the SEC you are aware of this. It just does not make sense to take away from the individual investor his ability to minimize his risk by selling. Fair disclosure and fair redemption prices that accurately assess the real cost of short term redemptions is much better than a one size fits all strait jacket that will reward the big fund companies and cost every one else a lot of money and headache and loss of capital.