Subject: File No. S7-09-20
From: Jill D.

January 3, 2021

I have a concern about the bar chart.
Supposed there are 2 identical funds (Fund A and Fund B). They are both SP 500 funds.

Fund A has a 10 year old class with a 5% front end load and has a no load class that is 5 years old.

Fund B has a no load class that is 10 years old and a class with a 5% load that is 5 years old.

Suppose both funds had the same performance, why should Fund A be required to reflect a load and Fund B not be? How is that a fair comparison?

This is not an issue in the prospectus because the bar chart does not reflect loads and the table shows all classes.