Subject: File No. s7-12-18
From: Carl Waranowski

November 25, 2018

OVERALL INVESTOR EXPERIENCE

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 do it myself. I buy Index funds and hold them for the long-term so I rarely, if at all, add or switch funds.
I learned that the two most important items for an investor to focus on is:
1. Asset-Allocation
2. Fees and expenses.
The Index funds may not accomplish this task perfectly but nicely.
I want to know, when buying a fund what the Expense Ratio is, Turnover percentage, "all-in" costs, how efficient it is tax wise, how closely it matches its benchmark/index and what index it is. For bond funds, similar to above, duration.

On the Morningstar site, I discovered "Diehards.org" which now is "Bogleheads.org" where I learned to make a non-correlated
portfolio based on making an asset-allocation plan and Investment Policy Statement. (IPS)
I follow the Vanguard, CNN business, CNBC, Dalbar besides reading many of the books on the bogleheads website.

I have not yet looked at the SEC 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?
Honestly, rarely.
I have found it very difficult to find the "all-in" costs. I had read in the Boston Globe Business page (2002?) that the
John Hancock Equity fund was charging a 2.20 ER however a $505 cost/$10,000/year was actually deducted which means
allot more expenses were taken out than the reported 2.20 ER.

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?
Speaking only for myself, I never relied on a disclosure or prospectus to select a Mutual Fund.
I have looked at funds on Vanguard, Morningstar to view a specific fund's stats and have found that relatively easy.
Generally, they are organized in 4, 5 or 6 sheets which cover what I need to know.

4. Do you use the advice of a financial professional? Does a financial professional's help affect whether and how you use fund disclosures?
I do not currently use a financial professional but have help at Vanguard, if I need it.
Due to past experience, I have a mixed experience in dealing with financial professionals with fund selection.
No crooks. (that I know of) Nice people. But not any better than I am picking funds.

DELIVERY

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?
Email, website availability.
If its important, mail delivery.

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?
What Index/benchmark it follows.
ER (Expense Ratio)
Turnover %
All-in cost
Tax efficiency
If International
% in EM Emerging Markets
% in DM Developed Markets
If Bonds
Duration (years)

7. How can the SEC better use technology and communication tools to help investors focus on important fund information?
Wow Don't know. A Julie Jason "Your Money" column article in the NH Sunday Union Leader business page brought me here
because I'm interested in the investing topic.
My 3 sons think the family newspaper is an anachronism.

Somehow, get an online (advertising?) space on WSJ, CNN, CNBC, FOX.
Try the newspaper too, I still read it

DESIGN

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?
Absolutely. Try to make it more reader friendly. Most people (me included) are turned-off by too much technical language.
A few key necessary graphs and charts are all that's needed.

9. Do you prefer to receive shorter 'Summary' disclosures, with additional information available online or upon request?
Sure, a summary should be short.

I get fund prospectus updates via email. Problem is, the way it is presented, you have read both prospectuses (before and after) in order to find out what the change is.

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?
You mean, like what did I "actually" pay in total fund fees, for say 2017? Interesting, sure.
Vanguard website tells me now that I pay 0.06 ER overall.
I can estimate, now, approx, what I actually pay.
Would I like to know precisely how much I pay? Sure I would.
I think Vanguard is transparent about it and not at all worried that I'm getting ripped off,
as what I am paying is very low.

However, I think many others, in other instit.'s might freak out if they knew what they were paying.

CONTENT

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?
Of course, anything to improve risk ratings and understanding them would be welcome.
I'm not sure that many people (including myself) know what "Alpha" or "Beta" or "R Squared" means?

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 think fund fees ought to be put in a prominent place and not buried on page 86 of 126 pages.
Disclosure of "all-in" costs would be welcome.
Sure a comparison of costs would be great How about against "3" choices?

13. Do you consider the past performance of a fund when making an investment decision? How could we improve the presentation of performance information?
All fund prospectuses say "past performance" does not guarantee "future performance".
Sure, you can put it in there but I'm not sure it means much.
Still needs the disclaimer warning.
You can never find or factor in all the funds per year which disappear due to poor performance.
Its why I'm a Indexer.

FINAL THOUGHTS

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 know it must be a tough job and respect the good work you do. Investors, like me, surely need help.

Next to Mutual Funds, the biggest issue in my opinion is Advisor directed accounts which charge AUM fees.

I would say, get online somehow. Yes, advertisers pay for space but you are Gov't. CNN, WSJ, CNBC, FOX
ought to be able to carve out a small space for you for free.