Subject: File No. s7-12-18
From: Roberto Delmonte

June 15, 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?
I use my broker's website, they have a tool that lets me sort fund by category, fees, performance and the like. For the area I want to invest in, I go for inexpensive funds, with good performance and high ratings.

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?
They is too much information provided to me. I buy a mutual fund because i want convenience and to more efficiently spend my time. Stop giving me hours worth of reading I do not understand.

I think all the information I need could be placed on a postcard.

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?
I do not use them. I like tools that help me compare funds. I do not pck funds in a vacuum, I select funds by comparing them to other funds.

4. Do you use the advice of a financial professional? Does a financial professional's help affect whether and how you use fund disclosures?
Financial professionals are not trushworthy and they gouge investors.


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?
Give me key bits of information (like on a postcard) and provide more online. DO not send me a notice every time some obscure document is posted. Save the notices for the bug stuff (like a drastic change to the fund).

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?

7. How can the SEC better use technology and communication tools to help investors focus on important fund information?
Lets innovators innovate. Stop being so prescriptive on how things should look and feel.


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?
Yes - disclosures should not tell us how smart a PM thinks they are.

All disclosures should be presented an an eighth grade level.

9. Do you prefer to receive shorter 'Summary' disclosures, with additional information available online or upon request?

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 ideal.

They should show me the big picture for all of my investments. The performance, fees, the major contributors and detractors from performance, and the risks.


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?
Strategies should be limited to a sentence or 2 (at least in the document sent to me).

A risk measure would be nice both for my finds and for my entire portfolio.

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?
I am not sure fees and expenses are an honest meausure of anything.
They do not count transactions fees. They do not account for the idea of spending money to make money. If securities lending brings in additional income, why do we list it as an expense which make the fund looks more expensive?

Also, there are too many different classes that makes any fee analysis very difficult to perform.

13. Do you consider the past performance of a fund when making an investment decision? How could we improve the presentation of performance information?
Yes. We should consider it. What else do we have to compare funds? Fees do not tell the entire story. Strategies and Risks are not great tols to differential funds in the same peer group.

It is also interesting the the SEC and investor groups downplay performance, when the supreme court require that boards consider performance in the Gartenburg factors.


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?
I like Europe's KIID. We should copy elements from it.

I think we should also do investor testing of various alternatives. I also like the idea of this feedback flier.