From: William Hepburn [hwt4@qwest.net]
Sent: Tuesday, February 03, 2004 7:12 PM
To: rule-comments@sec.gov
Subject: ile No. S7-26-03

I am a registered investment advisor mostly serving clients of moderate means.  I believe 
the proposal to require more specificity of mutual fund restrictions is a good one.  
Disclosure never hurts.

However, the proposal to allow fund companies to have minimum 2% short term redemption 
fee, however is a miscarriage of justice.  Imagine how it will look if Congress or the 
SEC rewards the subjects of all the scandals with a new revenue stream.  That is not 
exactly a deterrent, it is an incentive, and will smack of cronyism of the worst sort.

I also believe that redemption fees should bear close resemblance to the actual cost of 
the short term redemptions.  They should be structured allow funds to recoup bonafide 
expenses, but should not become a profit center or not be punitive toward selling 
shareholders.  After all, the mutual fund should have a fiduciary duty to all its 
shareholders, whether they are buying, selling and holding.   Gouging departing 
shareholders is hardly the act of a true fiduciary.

As an RIA, I am not allowed to stick it to clients on the way out the door.   I must be 
scrupulous in my accounting and fiduciary duties.  So should the fund companies.

Will Hepburn, CFP
The Prescott Center for Adaptive Market StrategiesTM

805 Whipple St, Suite D, Prescott, AZ  86301
Voice 928.717-0007,   Toll Free 800.778.4610
email Will@Hepburn.com,  Fax 928.778.0085
 
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