From: Skylark04@aol.com
Sent: Wednesday, June 23, 2004 11:00 PM
To: rule-comments@sec.gov
Cc: IanmcDonald@wsj.com
Subject: Mutual funds (s7-11-04)

As a former state examiner for almost a quarter century I would suggest that the 
mandatory redemption fees go to a fund run jointly by NASSA and the SEC to fund 
education and coordination of states and the Commission.  I feel that the 
cooperation between the SEC is more phantom than real.

 I can't speak of my own personal experience 1977-2000; but conversations I have 
had with branch managers and the like since leaving the State Commissioner's 
office lead me to believe that state staffs are beyond compare in their lack of 
training and their ability to report findings to the Commission rather than have 
the issues remain intra state. 

Parenthetically, I believe that to say  the Investor Protection Trust's effort  in 
getting going with an investor education program funded by settlement moved at a 
snail's pace is to libel snails. I think the redemption fee should only be used to 
make the states and the SEC get to know each other so that consistent coordinated 
efforts can be undertaken. 

My belief is that the SEC has for years ignored the states and then criticized 
them when they took action because the action threatened "consistency" of 
securities regulation.

How pray tell are the states and the SEC to achieve consistency without 
congregation, consultation, more joint exams and hotlines between the states and 
the Commission? 

Raymond Gambel