Subject: File No. S7-11-04
From: Karyn Hoffman

March 5, 2004

As things progress, the mutual fund companies are now instituting their own rules for how many exchanges a client can do within a quarter/year/etc.

In one case, Evergreen funds told me if a client moved funds out of the money market to make a new purchase, not an exchange, and they paid a sales charge to do so, it would still be considered an exchange.

What we forsee happening at this point is that each fund family is making up its own rules. This will be crazy for us to track all the different rules for different fund companies.

My question is--as these issues are hashed out, will there be uniform industry-wide rules and regs on this issue? Seems like that would be more efficient for all parties and easier to regulate than having each company self-regulate and make up its own rules.