Subject: File No. S7-08-18
From: Janice Daunheimer

August 7, 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?:
It makes it more clear to a beginner investor what they are signing on for.

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: For a novice investor, all terms that seasoned investors take for granted, are new to them. Consider making the language as simple as possible.
b. Our Obligations to You: Useful: Same as above
c. Fees and Costs: Useful: As a document it puts the responsibility on the consumer to ask the questions. I think companies should be required to provide the exact fees in writing and should be required by law to do so.
d. Comparison to different account types: Useful: Again, for the "newbie", which is who you should be gearing this to, the language can be confusing until they have already had some experience in the financial markets. The broker or advisor will probably hand over such a document while putting their own spin on it.
e. Conflict of Interests: Useful: As a consumer, I would be aware that there are many conflicts of interest that I would have no way of knowing if they were being adhered to. I remember a time when a broker I used was told to sell me every new fund his company compiled, with extra incentives for him if he did so. Many did not fit my needs in hindsight. I would have had no way to know he was doing this without having done some checking on my own.
f. Additional Information: Useful: If that were included it would offer some good questions to ask the broker/advisor, but you would have to trust his integrity to tell you the truth and this is someone you have just met. I think having consequences somehow for the broker/advisor, that were enforceable, would help with the trust issues.
g. Key Questions to Ask: Useful: Same as above

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:
d. Should the Relationship Summary include additional information about different account types?: Yes: Whatever it takes to be clear. Are there other types of accounts that should be addressed? For instance Merrill Lynch now has a "Self-Directed" account which, in my opinion is open to interpretation for responsibility for each type of function used, as well as any fees involved.
e. Would you seek out additional information about a firm's disciplinary history as suggested in the Relationship Summary?: Yes:

4. Are there topics in the Relationship Summary that are too technical or that could be improved?:
Addressed as we went along

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?:
I would like to see a list of applicable websites for discerning disciplinary websites or anything else that would additionally educate a consumer.

6. Is the Relationship Summary an appropriate length? If not, should it be longer or 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?:
The Financial Industry can be a minefield for beginners and it usually takes losing money to begin to learn the ropes. Anything that will either hold the industry itself more accountable to the consumer or the government or create a way of presenting material to the average consumer in a language they can understand, would be really useful.