Subject: File No. S7-09-18
From: Jeffrey Guella, CFP

July 30, 2018

In regards to "Provision of Account Statements" and including fees in these statements:

Custodians often already provide fee information on account statements and we periodically review fees with our clients, any additional requirements in this area would be a duplication (or triplication) of existing efforts.

Sincerely,
Jeff