Securities & Exchange Commission
Attn: Jonathan G Katz
  Adrian Burbage
P O Box F42627
Freeport, Bahamas
Tel: 1-242-373-5778(wk)
Fax: 1-242-373-1364
21st January 2004

Dear Sir

Re: Rule S7-26-03 - market timing rule

I am very pleased that the SEC will be acting to curb the Late Trading and the short-time in and out buying and selling of Mutual Funds. These practices are what most people would consider `sharp practices' and individuals and companies should be heavily fined if they engage in these actions.

However, as a small investor, presently less then $50,000, I review the funds I hold over the period of a month and then decide to hold, sell or buy - I do not consider myself a `Market Timer'.

Should the rules be changed to ensure that funds have to be kept for a minimum of 3 months, all us small investors would suffer, as I'm sure the bigger investment companies would find a `technical way' around these rules. Similarly a 3% redemption fee is exorbitant considering that some fund don't increase by that in a year - where is the incentive for fund managers to do their job properly if they know they have your money for 3 months!!

Can I suggest that a 7 - 10 day period be adhered to? This will stop the frequent in and out buying and selling of funds, usually done after hours and into the next day in order to make a short term profit. Some companies also put a 1% fee on funds held less then 30 to 60 days - although I think that ½% would be more reasonable if it is required to cover the administration costs.

Also some companies charge a 1% redemption fee if the fund is held for less then a year - and then add onto that a 2% 60 day fee, resulting in them getting 3% should I sell my fund within 60 days - I believe the SEC should also examine this `sharp practice' by the fund companies.

I hope my opinion is of interest to you.

Many thanks

Adrian Burbage