From: mleighton@capitalanalystsne.com
Sent: Thursday, April 08, 2004 3:29 PM
To: rule-comments@sec.gov
Subject: Proposed Rule S7-06-04

Dear Mr. Katz:

I am a registered representative who has 23 years of experience in the
investment business.  This letter is to inform you of my concerns
regarding the proposed new rules for point-of-sale and confirmation
disclosures of mutual fund transactions.

The following points summarize significant problems inherent in the
proposals:

1.   First and foremost, if all of the proposed rules are adopted and
implemented, it is clear that there would be significant cost increases to
all broker-dealers which ultimately will be passed on to the consumers.

2.   The current disclosures inherent in existing customer paperwork are
already complex.  The proposal to further detail disclosures appears to
create an even more complicated investment decision-making process for the
customer.

3.   The disclosure requirements are repetitive.  This proposed process
will deluge customers with the same paperwork over and over through the
investment process.

4.   Affiliate arrangements and practices are challenging to monitor.

5.   Implementation to comply with the proposed rules requires extensive
changes to existing software systems.  The SEC estimates over $780,000 on
average per broker-dealer as a one-time cost and an annual cost thereafter
of about $540,000.  These costs would ultimately be passed on to
customers.

I respectfully request that the Commission not approve the proposed rules.
It is clear that these proposals will only confuse the investing public,
and ultimately result in high costs to the consumer.

Sincerely,


Merrie J. Leighton