Subject: File No. S7-08-18
From: Mark Winsor

July 21, 2018

1. Overall, do you find the Relationship Summary useful? If not, how would you change it? If so, what topics and how can they be improved?:
Overall it may be useful if clients would read and understand it. Since I already explain to each client what they need to understand based on their situation, this seems like just one more document to overwhelm the client with the amount of information given to them to fulfill regulatory requirements. This may be fine for savvy clients with large amounts to invest but for the typical unsophisticated client that only has a small amount invested in accounts that require such disclosures, it burdens them and the advisor enough to dissuade the advisor from taking them as a client. This leaves those people, who represent the largest portion of the population, without competent advice.

2. How useful is each section of the Relationship Summary? Please consider explaining your responses in the comments:
a. Type of Relationship and Service: Useful:
b. Our Obligations to You: Unsure: Sophisticated clients may benefit, but this may confuse unsophisticated clients and may dissuade an advisor from taking unsophisticated clients because of the burden verses reward analysis.
c. Fees and Costs: Unsure: Sophisticated clients may benefit, but this may confuse unsophisticated clients and may dissuade an advisor from taking unsophisticated clients because of the burden verses reward analysis.
d. Comparison to different account types: Unsure: Sophisticated clients may benefit, but this may confuse unsophisticated clients and may dissuade an advisor from taking unsophisticated clients because of the burden verses reward analysis.
e. Conflict of Interests: Unsure: Sophisticated clients may benefit, but this may confuse unsophisticated clients and may dissuade an advisor from taking unsophisticated clients because of the burden verses reward analysis.
f. Additional Information: Unsure: Legal events should be separated from disciplinary events. For example, an advisor paying regularly on a tax lien should be viewed differently than an advisor who was disciplined for failure to properly care for a client. The client could mistakenly believe that the tax lien is a discipline issue because of the way they are lumped together.
g. Key Questions to Ask: Useful:

3. Please answer the following questions. Please consider explaining your responses in the comments:
a. Do you find the format of the Relationship Summary easy to follow?: Somewhat:
b. Is the information in the appropriate order?: Somewhat:
c. Is the Relationship Summary easy to read?: Somewhat: Depends on the sophistication of the client.
d. Should the Relationship Summary include additional information about different account types?: No:
e. Would you seek out additional information about a firm's disciplinary history as suggested in the Relationship Summary?: Somewhat: It depends on the relationship of the client and advisor.

4. Are there topics in the Relationship Summary that are too technical or that could be improved?:
Yes, depending on the sophistication of the client. Consider using the form for more clients who have larger accounts and not require it for smaller accounts.

5. Is there additional information that we should require in the Relationship Summary,such as more specific information about the firm or additional information about fees? Is that because you do not receive the information now, or because you would also like to see it presented in this summary document, or both? Is there any information that should be made more prominent?:

6. Is the Relationship Summary an appropriate length? If not, should it be longer or shorter?:
Shorter

7. Do you find the 'Key Questions to Ask' useful? Would the questions improve the quality of your discussion with your financial professional? If not, why not?:

8. Do you have any additional suggestions to improve the Relationship Summary? Is there anything else you would like to tell us?: