Subject: File No. S7-11-04
From: Daniel J. Clemons, CFP

March 9, 2004

The best way to handle market timing issues is with rules, regulations, and fines. Imposing short-term trading fees hurts all investors wishing to sell their shares within the five day period. I have had the occassion to sell or exchange a fund within that period because a certain sector fund begins to fall below a stop loss.

I am opposed to this rule because it would:

1. Gurantee a loss if sold in five days hurting all investors large and small.
2. Prevent reballancing of fund portfolios within a five day period.

How about amending the proposal to exclude the small investor by charging a 2 early redemption fee on amounts greater than 250,000?

Please dont let my comments fall on deaf ears.

Thank you,

Daniel J. Clemons, CFP
Serving the small investor