February 23, 2020
INVESTMENT ADVISER MARKETING FEEDBACK FORM
1. Have you ever hired, or considered hiring, an investment adviser? Because investment advisers are the subject of this proposed rulemaking, please focus your responses in this questionnaire on investment advisers rather than brokers. : Yes
2. Have you viewed any investment adviser advertisements? For example, have you looked at an advisers website or a presentation? : Yes
3. Have you looked at an advisers past performance results when considering hiring an investment adviser?
4. Have you ever specifically requested past performance results from the investment adviser? : Yes
5. If you have viewed an advisers past performance results, have you discussed them with the adviser? : Yes
6. If you have viewed an advisers past performance results, did you believe that those past performance results would predict the future performance that the adviser could achieve for you? : Yes
7. How important is it to know the following information when reviewing the past performance results of an adviser?
Performance results minus fees and expenses (i.e., net performance) : Very Important
A schedule of the specific fees and expenses deducted to calculate net performance : Very Important
Performance results for one-, five-, and ten-year periods : Very Important
Other information (if any, please describe) : What compensation the adviser receives from firms whose investments they recommend, including their own Broker/Dealer. It also would be important to understand, if presenting performance for actual clients, the results for assets for which the advisers had investment discretion. That is, you would want to distinguish between performance that resulted from the adviser's recommendations versus those from investments already held by the client. For example, if a client already held Apple stock when they became a client of the adviser, the stock should not be included in the adviser's performance results. I also think it would be very helpful to know who is actually making the investment recommendations. That is, advisers may rely on models provided by their Broker/Dealers or RIAs or 3rd parties. I believe clients have a right to understand that.
8. Have you reviewed hypothetical performance results that demonstrated how an investment strategy could have or would have worked?
If yes, did you discuss with the adviser how the adviser calculated those hypothetical performance results?
9. Have you reviewed targeted performance returns or projected performance returns?
If yes, did you discuss with the adviser the underlying assumptions on which those targets or projections were based?
10. Would other peoples opinions of the adviser (e.g., testimonials by advisory clients, and endorsements by non-clients), or an advisers rating by a third-party (e.g., Rated B+ by Adviser Reports) help you choose an investment adviser? : Yes
11. How important is it to know the following information when considering a testimonial, endorsement, or rating of an adviser?
Whether the person giving the testimonial or endorsement is a current client : Very Important
Whether the adviser pays the person giving the testimonial, endorsement, or the rating : Very Important
How recent the rating is, and the period of time it covers : Very Important
Other information (if any, please describe) : How long the person giving the testimonial has been a client and what services the adviser has provided the person. The methodology, if any, used to create the rating should be fully disclosed.
12. What other information do you think would make the advertisements not misleading?
13. Has a paid salesperson (a solicitor) ever referred you to an investment adviser? : No
14. Would it affect your decision to hire an investment adviser if you knew that the adviser paid a salesperson to refer you to the adviser? : Yes
15. How important is it to know the following information about a paid salespersons referral?
Amount paid to the solicitor for referring you to the adviser : Very Important
Whether there will be any additional cost to you: Very Important
The solicitors relationship to the adviser : Very Important
Whether the solicitor has been disciplined for financial-related misconduct : Very Important
Other information (if any, please describe) : How long the solicitor has known the adviser and how many clients the adviser has gained through the solictor's introduction.