From: Paul Cunningham [paul@icon.net]
Sent: Tuesday, April 20, 2004 2:22 PM
To: rule-comments@sec.gov
Cc: Paul Cunningham
Subject: File No. S7-11-04 - My Thoughts on the Proposed 2% Redemption
Rule

Ladies and Gentlemen:

In my opinion, imposing a 2% redemption penalty on mutual fund shares
redeemed within 5 days of purchase will do more harm than good.

I urge you to consider other ways to correct the problem.

Paul Cunningham
Merit Advisors, Inc.
Oklahoma City, OK