Subject: File No. S7-09-15
From: Jeff J Diercks

May 22, 2015

This amendment is unnecessary busy work for smaller advisors who do not have a team of compliance professionals on staff. I also seriously doubt the changes designed to provide enhanced separately managed account business reporting do anything to catch the next Madoff or make for a more secure investment environment for clients.

I can tell you definitely that a very small percentage of prospective clients ever even bother to read the Form ADV part I or II, even though it is provided to all of them. They are not sophisticated enough and too time challenged.

My suggestion is you work on simplified reporting that they (the prospective client) can read in 1-2 pages. That is unfortunately, their attention span today.