August 31, 2020
1. Overall, would the sample shareholder report be useful in monitoring your fund investments? If not, how would you change it?
Yes. Once a year is enough.
2. Rate the sections of the sample shareholder report. Please indicate whether you find each section useful or not useful. Please consider explaining your responses in the comments.
a. What was your cost for the period? : Useful : Can be more succinct. Just give the cost figure.
b. How did the Fund perform last year? What affected the Funds performance? : Useful :
c. How did the Fund perform over the past 10 years? : Useful : Though hard to compare when many funds have not been around for 10 years, but I guess that is what the table is for.
d. What are some key Fund statistics? : Useful : Consider adding standardized metrics for different fund types (like ESG scores, yields, duration, etc.
e. What did the Fund invest in? : Useful :
f. How has the Fund changed? : Useful :
g. How does the Fund ensure that it has money available to pay me when I exit the Fund? : Not Useful :
h. Where can I find additional information about the Fund? : Useful :
3. The section titled What was your cost for the period? includes an example of what it costs to hold fund shares this year.
a. Is the table clear? Yes
b. Is it helpful to see costs paid both in dollars and as a percentage of your investment? Yes
c. Is it clear how the total returns of the fund minus the costs paid result in the ending account value? No
4. The section titled How did the Fund perform last year? What affected the Funds performance? includes narrative and graphic presentations
a. There is a narrative description of the funds past performance in the Performance Highlights section. Does the narrative description help you understand the key drivers of fund performance? Yes
b. There is a graphic presentation of key drivers of the funds past performance in the Performance Attribution section. Does the graphic presentation help you understand why the fund performed as it did over the past year? Yes
c. There is a line graph representing the funds performance in dollars over the past 10 years. Does this graph help you understand how the fund performed over that time period? Yes
d. There is an Average Total Returns Table showing the funds performance as a percentage over the past 1, 5, and 10 years. Does this table help you understand how the fund performed over those time periods? Yes
e. Is it helpful to see the funds performance both in dollars and as a percentage? Yes
Is there any information that could be presented more clearly in the How did the Fund perform last year? section?
Costs. Also our performance numbers before performance explanation.
5. The sample shareholder report includes key statistics about the funds size, number of investments, and annual portfolio turnover. Do these statistics provide meaningful information regarding the fund, for example, to help put the funds performance and investments into context? Yes
6. The section titled What did the Fund invest in? includes charts describing the types of investments made by the fund. Do these charts help you understand how the fund is investing your money? Yes
7. The section titled How has the Fund changed? describes important changes to the fund within the last fiscal year. What types of changes are most important to you?
how the fund invests. Anything that changes the deal on investors.
8. Is there any information in the sample shareholder report that is difficult to understand, confusing, too technical, or that could be presented more clearly?
Liquidity disclosure, fee portion of costs
9. Is there additional information that we should require in the shareholder report? This could include the funds full financial statements, the results of any shareholder votes and/or how much the fund paid to directors, officers, and others. Is there any information in the sample shareholder report that should be highlighted more?
10. Under the proposal, in addition to the shareholder report, you also would have access to more information about the fund online (and delivered in paper on request). How likely would you be to seek more information on the following?
The funds full financial statements : Very Unimportant
Key financial information over time : Important
Changes in and disagreements with accountants : Very Unimportant
Results of any shareholder votes : Very Unimportant
How much the fund paid to directors, officers and others : Very Unimportant
11. Is the length of the document:
About right
12. How would you prefer to receive or read a document like the sample shareholder report?
A combination of paper and digital
13. Do you have any additional suggestions for improving the shareholder report?
I think the flier is biased in favor of folks that want digital materials. It is available online, the sample is online, you can only find the release online, and I only read about all this online. I think this flier is a good approach just be mindful of the answers you will receive and dont assume it is a good cross-section if the population.