From: Kelly Higgins [kelly@c4fm1.com]
Sent: Wednesday, May 05, 2004 5:10 PM
To: rule-comments@sec.gov
Subject: S7-09-04

1.		Rule 12b-1 Has Allowed Shareholders to Receive Ongoing 
Professional Services -particularly those shareholders with relatively smaller 
mutual fund investments.  The receipt by broker-dealers and their 
representatives of 12b-1 fees has enabled these shareholders to receive 
ongoing professional services which would otherwise not be available to them 
or only available at additional costs to these shareholders.  These services 
include not only administrative services, such as providing, changing or 
correcting account information, but also substantive assistance through the 
provision of analysis and financial planning for these shareholders.  Without 
the 12b-1 Fees, we would not be able to provide these services to our fund 
shareholder clients at all or without imposing charges for these services.   
The elimination of 12b-1 fees would also likely result in reduced attention 
paid to fund shareholders, in the overall marketplace, after the sale.

2.	Rule 12b-1 Aligns Shareholder and Advisor Interests - The interests of
fund shareholders are best served by aligning the interests of the advisor
with the interests of their fund shareholder clients.  This is best achieved
through the receipt of Rule 12b-1 Fees as opposed to the need for additional
charges to fund shareholders for these valuable services.


Kelly L. Higgins
Financial Advisor
Retirement Specialist

Center for Financial Management One, L.L.C.
37711 Hanson Drive
Sterling Heights, MI  48310
(248) 649-1144
(586) 795-1599 fax
kelly@c4fm1.com