Subject: File No.
From: William Michael Cunningham,
Affiliation: Creative Investment Research

February 5, 2018

We refer the Commission to the following:

Amicus Brief in Fiduciary Rule Case (16-cv-1035). See:

Amicus Brief in Met Life v FSOC (16-5086). See:

Amicus Brief in US vs. SP (US District Court, Central District CA)

Testimony on the Fiduciary Rule at the Department of Labor:

We incorporate the above by reference.

Thank you.