From: Brian [brian@gobcafunds.com]
Sent: Wednesday, March 17, 2004 9:24 PM
To: rule-comments@sec.gov
Subject: File No. S7-11-04

Sorry guys, but what the heck are you thinking. I know you have many 
responsibilities, but I don't think you put a great deal of thought into this 
rule.  The intent, I think is good, the plan is not so good. It opens the door 
for fraud, fund company misappropriation and will not help fund investors. 
Sooner, rather than later, improprieties will arise from the misuse of the 2% 
collected in fees. I believe you are trying to prevent people from engaging in 
"international arbitrage", or capitalizing on stale pricing by fund 
companies.This problem should be decentralized and dealt with a the fund company 
level.  First, they need to have a prudent pricing methodology in place to keep 
international prices at fair market value. Also, fund exchange policies should 
be clearly defined in the prospectus. In ENGLISH, and consistent among all the 
funds within their family. People are smart, they can decide which fund company 
best suits their investment philosophies. This is America, we have the right to 
make well informed decisions with our capital. We don't need legislators trying 
to make things better, by inadvertently making things worse for the average 
mutual fund investor. Brian Carruthers