Subject: File No. S7-15-18
From: Jack Reagan

July 12, 2018

I agree with this proposal.

I do suggest a few changes:

1. Instead of making a fund fee table even more complicated by adding bid/ask spread (which may not be indicative of the actual bid/ask spread you might pay at a given time), instead edcuate investors (thru disclosures) that ETFs (and all traded vehicle do not trade at a single price, but instead explain the concept of a bid and ask price.

2. All holdings and basket information should be filed in a central location (such as EDGAR) in a common format. It is too difficult to search many funds groups for this information and then putting it in a common format for analysis. A central repository wold also provide a historic record.

3. Make easier for new APs to enter the market.