September 30, 2021
I would like to propose to amend the requirement of the Part 2B of Form ADV: Brochure Supplement, Item 2 instruction to disclose the supervised persons \"age (or year of birth)\". The publication of this information, more so with year of birth which is most common, creates a privacy and security risk to the supervised person and promotes age discrimination. An investor can discern the material nature of a supervised person's qualifications, education and background from the other information included in the 2B and by meeting with the supervised person, whether in-person or virtually. The risk posed to the supervised person and potential negative bias outweigh the publication of this information.