August 20, 2020
I want to congratulate the SEC staff on the redesign of the Annual Shareholder Report. As someone who has worked with Fortune 500 public companies to meet SEC regulatory requirements for clarity, I applaud this new effort. Thank you also for eliminating all the information that's intended for financial advisors/brokers rather than for the investor.
I would like to make one suggestion: Some of the language could be modified even further. For example, XYZ Income Fund returned 6.45% for Class A and 6.70% for Class Z for the 12 months ended January 31, 2020. The Fund underperformed its benchmark (the QRS Aggregate Bond Index), which returned 7.72%. This underperformance is largely the result of our portfolio holding more interest–rate-sensitive investments than our benchmark. Instead of "interest-rate-sensitive investments," perhaps you could say "...largely the result of our portfolio holding investments that increase and decrease due to changes in the interest rate." That's my interpretation of what "interest-rate-sensitive" means. I could be wrong. But then that's the point.
In any case, thank you for this historic change.
Deborah S. Bosley
Founder and Principal
The Plain Language Group, LLC