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

April 6, 2004

Have you stopped posting comments online? I do not see any comments after March 25th, and I know I have sent one since then. Here is another installmment of the Time Zone Arbitrage Follies
So Friday, April 2nd was a big day in the US mkts with a strong employment report. Averaged together the SP500 and Nasdaq100 gained 1.7. Great Using the Time Zone Arbitrage Theory I should buy international mutual funds because, due to stale prices these funds are due to rise on Monday. I have 15 international funds shown that rose on average 0.00. Thats right, no gain. And what is funny, most international indexes were up. Of course, what the Time Zone Arbitrage Theory forgot to say was that it only works when the dollar is stable or sliding versus foreign currencies, which was not the case Monday. Since there are many extended periods when the dollar rises, there are many times when this theory is worthless, or would even cause an investor money. This theory should not be used as a basis for expensive and needless regulation. The Washington Post had an editorial on March 27th about Europes regulation of Microsoft, which it felt was improper. The editorial ended with this quote: When there is not a clear need for government interference in the marketplace, the better policy is to not interfer.

Sounds like good advice. Again, this proposed rule is bad policy and bad politics. It will harm the individual investor, cause his degree of risk to rise, and reward the fund companies who caused this problem. Please do not instigate this rule. I did like the suggestion by some that said since the problem was caused by big money, only apply the rule to transactions above 1 million. Still bad policy and politics, but at least it leaves the small investor out of it. I would appreciate the opportunity to talk to you in person. Respectfully Submitted, Darrell D. Wiard
1-Apr 2-Apr 5-Apr 6-Apr
SP500 1132.17 1141.81 1150.57 0.85
NDX100 1453.22 1490.3 1508.37 2.55 1.70 gain on 4/2
Aetna Intl 7.38 7.38 0.00 gain on 4/5
AmCentIntl 8.49 8.45 -0.47
Fid Adv Intl 16.67 16.68 0.06
AIM EuropeanGrowth, #230 24.24 24.22 -0.08
AIM Intl EmGr, 1528/3528 13.5 13.57 0.52
Artisan Intl 20.33 20.22 -0.54
FNORX-NordicFund342 23.48 23.45 -0.13
FIEUX301-Europe3 28.33 28.32 -0.04
EurCapApp341 19.81 19.73 -0.40
Putnam Intl Gr 21.57 21.65 0.37
FIGRX305-IntlGrowth/Inc2 25.61 25.63 0.08
FWWFX318-Worldwide3 17.18 17.25 0.41
FDIVX325-DiverIntl 26.09 26.09 0.00
FOSFX094-Overseas3 33.83 33.84 0.03
FIVFX335 - Intl Value335 16.22 16.24 0.12