Subject: File No. s7-12-18
From: Betsy Sachs

June 13, 2018


1. How do you pick funds? What information do you want to know when you make an investment in a fund? What publications or websites do you review? What tools, online or otherwise, do you use? Do you look at the SECs website?

2. Do you read current fund disclosure documents? Do you understand them? Is there information you do not receive from the fund that you would like to get?

3. How well do current fund disclosures (such as a summary prospectus, prospectus, or shareholder report) help you pick an investment? Is it easy to compare different funds? Are there technology-based tools that could make fund comparisons easier? What helpful features do those tools have?

4. Do you use the advice of a financial professional? Does a financial professional's help affect whether and how you use fund disclosures?
If you have never suffered life altering loss at the hands of someone you trusted with your savings you might have difficulty understanding. The issue is complex and many do not understand what has happened or why it has been allowed to happen. Being taken advantage of by someone you placed your trust in is a terrible betrayal. We do not have the means to replace what was lost. We have been manipulated, railroaded and cornered and I don't think our concerns have been addressed. The investor is intimidated to protect the industry. Whether it's a physical or financial violation the impact is devastating. The entire industry is the largest government approved fraudulent scheme still operating. It's a total scam putting investor interest secondary to the companies' well-being and profit. A clever bait and switch can be found behind all investor financial assault. There are trauma and health effects on victims of financial assault upon learning you have very little chance for fair and honest treatment by the industry and those who enable it. This is a major socio economic issue. Our savings were decimated by the willful acts of an investment industry gone terribly wrong. Fraud and wrongdoing by the "regulated" financial industry is a tragic story. The financial services industry is based on financial product sales rather than providing financial advice. The status quo allows advisors to harvest investor savings without restriction. Financial advisor is an unregulated business title used by salespeople to gain trust. Regulators do not get victim's money back, mechanisms for restitution are industry controlled, and victims are not treated fairly or with courtesy. An accredited investor is not always a person that can deal with securities not registered with financial authorities. Beneath the crust of superficial piety is a corrupt and increasingly dysfunctional system.

There was deceit by representation in our Finra Arbitration. Finra Arbitration Clinics are set up for small claims not $600,000 losses like we had at the time before we lost an additional $195,000 in account value during the transfer to another firm because of our advisor's use of margin with a - $72,000 margin balance and the account taking 4 months to settle. 58 of 60 exception notices went unanswered and Finra looked the other way. That advisor claimed no fiduciary duty yet he secured for us a predatory fast and easy liar's loan, used our stock portfolio as collateral and charged us $130,000 in fees and commissions and $35,800 in margin interest. He was arrested during the timeframe he lost $300,000. Additionally, this advisor has three settled cases in BrokerCheck for selling just to make commissions. An advisor commits fraud when he makes a misrepresentation he knows is false. The fieriest circle of hell is reserved for advisors and brokers. Was it appropriate to spend the kind of money we did to have this result? We are in an emergency situation that needs to be managed. How can we possibly repair our fragile, broken over- leveraged balance sheet? Jargon is often the preferred method of the financial community to make themselves sound more intelligent. "Just trust me, I've got this" worked in the past before the internet. Investors want to earn the highest possible returns while using the lowest amount of risk possible. Investors generally do not have a good appraisal of what a legitimate benchmark should look like. Our former firm lacks sufficient training of supervisory managers and staff about conflicts of interest requirements and staff compliance responsibilities. This whole ordeal is an awful thing to have gone through. Fund managers have been found less savvy than widely assumed. Many have little or no experience or even a basic understanding of how the market works. Experience in trading is the sum of many small to medium mistakes. Financial wipeout like we have experienced is the result of a larger one. There is always what you see and what you don't see. How can a less savvy consumer be helped by being blitzed by confusing advice from bottom feeders? Firms like our former are selling products and services that allow wrong doers to run amok. It isn't good for consumers. Advisors like our former are above the law and not held accountable to commit secret crimes and there's nothing you can do about it. The amount of energy necessary to refute horse manure is an order of magnitude bigger than to produce it. Procedures need to be mandated to prevent financial exploitation and abuse. Sales people should not be allowed to call themselves advisors unless they have proper licensing. Purchasing UIT's and closed end funds are not the best way to create a comprehensive financial plan. Laws and rules are needed to make sure the consumer has the ability to afford whatever the "advisor" gets them into. UIT peddlers beware.

Carl Icahn received an EPA hardship waiver worth tens of millions of dollars. Icahn's two refineries posted combined profit of $286M+$115M in the first 3 months of 2018. Misadvising allows fraud to pick the pockets of society by as much as all measured criminal acts combined. The investment advisor bait and salesman switch is a root cause of great economic fraud due to incentives to deceive investors. By paying a small premium of a few billion dollars to financial industry self-regulators, media, and others the investment industry purchases the silence of thousands of "handmaids" to keep the fraud hidden. A used car salesman speaks well, they're convincing but ultimately they are benefitting even if someone else is harmed by their advice. There are large and unnecessary hurdles for victims of financial crimes. 1% at best can identify economic or other cognizable harm based on specific violations of Federal Law. I can. It's completely backwards to let others decide who gets their money back and who doesn't by making victims of abuse prove their own case. To get their money back, consumers must prove their own harm and scratch to get repayment for mistreatment.

I had no idea of the appropriateness of our inherited advisor's transactions. No review of the transactions was held. The investments were outside guidelines. There were large weightings and individual security options trading, all red flags. The more data there is the less you can trust it. Most investment advisors are not allowed to make trades with out prior approval but ours did. The buying and selling of a security without proper consent of the client is considered unauthorized, discretionary and a violation. We had no crafted financial plan. Only a lunatic or egomaniac like our former advisor would impose his own lifestyle on someone else unless he's ready to assume a personal responsibility for the consequences. Turnover ratios exceeding 50-100% per year are inherently suspect in securities investment accounts. Big data may mean more information but it also means false information. The law should unambiguously require investment professionals to act in the best interests of their customers. We would have considerably more money if we simply bought an index fund. No one needs 278 financial products except the people selling them. People are led to believe the financial services industry will help them save for the future, that the industry will look after their best interests with fiduciary care, that they will be safe when they place their trust in an advisor, that the regulators will protect them and if fraud is found there will be mechanisms for restitution. People find the truth after they have been victimized that the industry focus is on selling financial products with commission salespeople, there is no responsibility to look after best interests, financial advisor is an unregulated business title used by salespeople to gain trust and regulators do not get victim's money back. Rigged system. Submitting to the fates, there is nothing more I can do to affect the outcome. We should all be curious what's possible when people try really hard to help each other tackle a seemingly impossible task. You build systems robust to the the assumption that humans are flawed self-serving and prone to being taken advantage of. Only the strong go crazy, the weak just go along. The things that change the world are tiny things like butterfly wings. Respectfully submitted,

The Federal Reserve and Consumer Financial Protection Bureau have forwarded complaints on our behalf to our mortgage lender and Finra and our case is included in the Federal Trade Commission data base used by law enforcement worldwide. Knowing you can maintain your current standard of living for the rest of your life gives real peace of mind. An advisor adds value by building a low cost diversified portfolio which reflects capacity for risk. Only when a client experiences good advice do they truly understand the value of an advisor. Money is nothing more than trust. A self-regulating profession must take very seriously our obligation to protect the public. This is more than a mere academic exercise but a rare opportunity. In every case involving "$100,000 or more one of the 3 arbitrators will be affiliated with the securities industry." Finra later conceded that" the industry Arbitrator might be a problem" so they created a "pilot program" to study the subject. Some cases (like ours, we got caught in the pilot program) were heard before a 3 person Arbitration panel that was all public. Three years later Finra studied the results and changed course again. Finra lacks authority to enforce. Congress deliberately withheld from Finra the power to bring enforcement cases for Securities Act violations. Laws and rules are needed to make sure the consumer has the ability to afford whatever the advisor gets them into. Closed mouths are never fed. This is rhetorical whiplash. It is important we keep calling out these abuses demanding investigations and accountability and winning reforms to prevent them from recurring. There is so much at stake. Financial literacy is financial education combined with the ability to employ these skills in making financial decisions. Many will never understand the precautionary principle because they believe themselves to be smarter than nature. Skin in the game is risk management for society. Respectfully submitted,


5. How do you prefer to receive communications about fund investments? For example, do you prefer mail delivery, email, website availability, mobile applications, or a combination?

6. What types of fund information do you prefer to access electronically? What types of fund information do you prefer to receive in paper? Are there other wayssuch as by video or audio, you would like to receive fund information?
interactive charts

7. How can the SEC better use technology and communication tools to help investors focus on important fund information?


8. Is there too much technical writing in fund disclosure? Would you prefer more tables, charts, and graphs? Would these graphic displayes be in addition to, or in place of, text-heavy disclosures?
most of it is superfluous

9. Do you prefer to receive shorter 'Summary' disclosures, with additional information available online or upon request?
I want to receive usable content regardless of the length.

10. Should fund disclosures be more personalized? For example, should disclosures show the amount of fees you paid or your actual investment returns? If so, how?
Yes this would be better if it reflected dollar amounts protracted.


11. Do fund disclosures make the fund's strategies and the level of risk clear? How can funds improve these disclosures? Would a risk rating, such as a numerical or graphical measure of risk, be helpful?
Never is the level of risk clear.

12. Fund fees and expenses can significantly affect a fund's investment returns over time. Do you think funds clearly disclose their fees and expenses? How could funds improve the disclosure of fees and expenses? Would a comparison of your funds fees against other funds fees help?
We have learned all about fund fees commissions and disclosures and they certainly do affect returns. Additionally, investors truly do not understand the importance of a true fiduciary standard and the impact not having one can have on accumulating and preserving wealth and financial security. You only need to be rich once.

13. Do you consider the past performance of a fund when making an investment decision? How could we improve the presentation of performance information?
Interactive charts can improve the presentation of information


14. Aside from this questionnaire, are there other ways the SEC can engage with investors, like you, on key topics? Is there anything else you would like to tell us?
1 % of investors can identify cognizable harm based on violations of Federal and State Laws. I can. I am standing in the shoes of The DBR to bring an enforcement action.