Subject: File No. S7-03-17
From: Jack Frei

March 13, 2017

I think tagging the risk/return summary in inline format has no value.

It appears the only folks who use mutual fund risk/return data is data aggregators, such as Morningstar and Lipper, who sells the data back to the industry.

There has been no evidence that the SEC staff, academics, or every day investors uses this data.

The fund industry is under enough pressure with liquidity regulation, possible derivatives regulation, the DOL rule, and SEC reporting modernization. Is adding inline XBRL on top of this necessary? I do not see the value add.