From: Stephen Granger
Sent: June 19, 2007
To: rule-comments@sec.gov
Subject: File Number 4-538 comments


Gentlepeople:

Please accept my $.02 worth re 12-b fees.

While they might have been justified in the past to market a new investment vehicle, they are not appropriate now that mutual funds so common they are the ONLY investment choices in almost ALL employer-sponsored retirement plans.

12-b fees now are about as appropriate as the recent 3% telephone excise tax that was initiated in 1898 to help finance the Spanish American War.

Stephen Granger