Subject: File No. S7-06-04
From: Dennis N Heffernan

February 25, 2004

SECTION B
1 The estimated first year asset-based service fee should show the percent paid as well as the dollar amount and indicate if the fee will be paid every year. Along the lines of:
After the first year the service fee ___will ___ not be charges annually

2 Is there any reason not to display the brokerage firms NORMs as the industry norms?

SECTION D
Add an additional question:
Is this sale eligible for an extra fee/commission from the fund or brokerage firm that will only be available until a certain date?

Having been registered Series 7 15 years ago, I think I recall incentives offered by fund companies on sales made during a specific month.

thanks, dennis