September 16, 2020
I do not agree with the presentation of fees in the annual report. The figure presented in the annual report is not consistent with the prospectus or what you intend to require in fund advertisements. An investor can it be expect to make sense of these differences.
For example, what is an investor to think when a lifecycle fund shows a fee of 0.15% if the annual report and 0.87% in the prospectus?
What if the annual report disclosed a fee of 0.15% fee on the first page and the third page states the fee of the fund will go from 0.87% to 0.75%?
Also in your advertising rules, require funds to use the fee terms in the prospectus instead of merely gross and net fees. The expression after temporary waiver will help investors understand the difference between gross and net.
Finally, I think major fund changes should be disclosed on the cover page (and better, require prior shareholder approval).