From: David E. Ross [david@rossde.com] Sent: Thursday, March 04, 2004 4:15 PM To: rule-comments@sec.gov Subject: S7-11-04: Comments: 1. Yes, the fee should be mandatory, universal, and uniform. 2. The exceptions should NOT include unanticipated financial emergency. This is too hard to verify and too easy to contrive or even fake. 3. The exceptions should include any purchases made via automatic transfers of dividends from other funds from the same fund group. I own several funds in the Vanguard Group. Dividends on several of them are automatically transferred to one of them. In this case, I should not be inhibited from withdrawing the amounts transferred. 4. Vanguard already imposes a similar fee on some of its funds. On some funds, the fee is applied only on redemptions via phone or Internet but not via letter sent through postal mail, for more than two redemptions in 12 months. It should be mandatory that any such fee (either through proposed rule 22c-2 or on a funds own initiative) must be applied uniformly without regard for how the customer initiates the transaction. Vanguard's exemption for redemptions via letter and postal mail puts customers living on the Pacific coast at a disadvantage with respect to customers close enough to Vanguards offices to have next-day delivery of postal mail. No such exemption should be allowed. 5. The five-day holding period should be market days, not calendar days. 6. Funds should be required to include the fee when computing sales loads, commissions, or other charges levied when fund shares are redeemed. That is, the charges should be based on the lower amount remaining to be paid the customer, after subtracting the 2% fee. 7. Better clarification is needed to ensure the 2% fee is retained by the fund for the benefit of the remaining share holders and is not to be used for the benefit of the fund management. David E. Ross Oak Park, CA 91377 David E. Ross I use Mozilla as my Web browser because I want a browser that complies with Web standards. See .