December 15, 2020
1. Overall, would the sample shareholder report be useful in monitoring your fund investments? If not, how would you change it?
Yes
2. Rate the sections of the sample shareholder report. Please indicate whether you find each section useful or not useful. Please consider explaining your responses in the comments.
a. What was your cost for the period? : Useful : I like seeing my actual cost. I just need the percent and dollar figure. I also think it should include the elements of the fee table such as underlying fund fees.
b. How did the Fund perform last year? What affected the Funds performance? : Useful :
c. How did the Fund perform over the past 10 years? : Useful :
d. What are some key Fund statistics? : Useful :
e. What did the Fund invest in? : Useful :
f. How has the Fund changed? : Useful : I think this should be in advance of any change.
g. How does the Fund ensure that it has money available to pay me when I exit the Fund? : Not Useful : They should have the money to pay me. They need not tell me how.
h. Where can I find additional information about the Fund? : Useful :
3. The section titled What was your cost for the period? includes an example of what it costs to hold fund shares this year.
a. Is the table clear? Yes
b. Is it helpful to see costs paid both in dollars and as a percentage of your investment? Yes
c. Is it clear how the total returns of the fund minus the costs paid result in the ending account value? No
4. The section titled How did the Fund perform last year? What affected the Funds performance? includes narrative and graphic presentations
a. There is a narrative description of the funds past performance in the Performance Highlights section. Does the narrative description help you understand the key drivers of fund performance? Yes
b. There is a graphic presentation of key drivers of the funds past performance in the Performance Attribution section. Does the graphic presentation help you understand why the fund performed as it did over the past year? Yes
c. There is a line graph representing the funds performance in dollars over the past 10 years. Does this graph help you understand how the fund performed over that time period? Yes
d. There is an Average Total Returns Table showing the funds performance as a percentage over the past 1, 5, and 10 years. Does this table help you understand how the fund performed over those time periods? Yes
e. Is it helpful to see the funds performance both in dollars and as a percentage? Yes
Is there any information that could be presented more clearly in the How did the Fund perform last year? section?
5. The sample shareholder report includes key statistics about the funds size, number of investments, and annual portfolio turnover. Do these statistics provide meaningful information regarding the fund, for example, to help put the funds performance and investments into context? Yes
6. The section titled What did the Fund invest in? includes charts describing the types of investments made by the fund. Do these charts help you understand how the fund is investing your money? Yes
7. The section titled How has the Fund changed? describes important changes to the fund within the last fiscal year. What types of changes are most important to you?
How it invests and fees.
8. Is there any information in the sample shareholder report that is difficult to understand, confusing, too technical, or that could be presented more clearly?
Costs could be simplified.
9. Is there additional information that we should require in the shareholder report? This could include the funds full financial statements, the results of any shareholder votes and/or how much the fund paid to directors, officers, and others. Is there any information in the sample shareholder report that should be highlighted more?
No
10. Under the proposal, in addition to the shareholder report, you also would have access to more information about the fund online (and delivered in paper on request). How likely would you be to seek more information on the following?
The funds full financial statements : Very Unimportant
Key financial information over time : Important
Changes in and disagreements with accountants : Very Unimportant
Results of any shareholder votes : Very Unimportant
How much the fund paid to directors, officers and others : Very Unimportant
11. Is the length of the document:
About right
12. How would you prefer to receive or read a document like the sample shareholder report?
In an email
13. Do you have any additional suggestions for improving the shareholder report?
I read that there should be more about fund directors. I disagree. That is more for their ego and wanting attention. A director is a mechanical function with occasional judgement calls. The report need to overemphasize backroom operations.
I also read that there should be more diversity on fu d boards and that should be reported. I disagree. Again boards perform a simple function. There should be more diversity in the asset management industry generally. Adding token individuals to a board to that meets once a quarter and is hugely overpaid is not the answer. The portfolio managers, accountants and offices should be more diverse. That should be the focus.