From: James Benton [jbenton@new.rr.com]
Sent: Sunday, February 22, 2004 7:16 PM
To: rule-comments@sec.gov
Subject: On "early redemption fees" (s7-11-04)

SEC:
 
I sincerely hope that you will refrain from making any ruling requiring the funds 
to make and enforce short term trading fees.  Among the funds I use are Rydex and 
Profunds, which are constructed to allow trading, and if such fees are required 
there you will only succeed in putting them out of work.  Those of us who refuse 
to hold funds that begin a hard trip down, despite the date of purchase, will 
migrate over to ETFs very quickly and abandon the old mutual funds altogether.
 
What we need is for funds to decide whether they wish to be trading funds or not, 
and to make that information public.  If they do not, they should have the choice 
of either a 1%-2% EWF or a ban on anyone making more than a certain number of 
withdrawals from a fund per month, or quarter.  
 
Again, please refrain from trying to make one general rule.  It will not be 
useful.
 
Yours,
Dr. James S. Benton
Wisconsin