Subject: File No. s7-12-18
From: CHIP MORTON

December 28, 2018

OVERALL INVESTOR EXPERIENCE

1. How do you pick funds? What information do you want to know when you make an investment in a fund? What publications or websites do you review? What tools, online or otherwise, do you use? Do you look at the SECs website?
I pick funds on fundamental historical performance information: Overall expense ratio and performance data detail, Turnover ratio, Detailed explanation of investment approach, Funds rating indicator.

I use AAII Journal and website, Morningstar website for non bias information. Brokers websites for other data including fund comparison tools.

I do not use the SEC website.

2. Do you read current fund disclosure documents? Do you understand them? Is there information you do not receive from the fund that you would like to get?
I read the fund prospectus and fund summary paper reports. I understand most of it.

Some prospectus reports do not include a full detailing of all the individual investments in the fund. I would prefer a more detailed report on all equity and bond investments in the fund. A better explanation of relative risk for investment method used.

3. How well do current fund disclosures (such as a summary prospectus, prospectus, or shareholder report) help you pick an investment? Is it easy to compare different funds? Are there technology-based tools that could make fund comparisons easier? What helpful features do those tools have?
Fund comparison tools are very useful and should be encouraged. I rely on independent fund analysis reports from independent third parties such as AAII or Morningstar for general fund analysis.
Some prospectus reports do not include a full detailing of all the individual investments in the fund. I would prefer a more detailed report on all equity and bond investments in the fund.

4. Do you use the advice of a financial professional? Does a financial professional's help affect whether and how you use fund disclosures?
I do not use the advice of a financial professional. There is still too much conflict of interest from your typical assigned brokerage advisor.

Fund disclosures are usually sent from a broker after I have made the investment on the brokerage site.

DELIVERY

5. How do you prefer to receive communications about fund investments? For example, do you prefer mail delivery, email, website availability, mobile applications, or a combination?
I Prefer mail delivery. I like to read and mark up paper copies.

6. What types of fund information do you prefer to access electronically? What types of fund information do you prefer to receive in paper? Are there other wayssuch as by video or audio, you would like to receive fund information?
I usually invest either in index funds or index ETF's. I do not spend allot of time analyzing stock or bond funds. I use these funds mostly for quick diversification of my portfolio's.

7. How can the SEC better use technology and communication tools to help investors focus on important fund information?
The SEC needs to do a better job of educating the individual investor on what tools are available or offered on their website to help in rating or analyzing funds.

DESIGN

8. Is there too much technical writing in fund disclosure? Would you prefer more tables, charts, and graphs? Would these graphic displayes be in addition to, or in place of, text-heavy disclosures?
Yes, I prefer more charts and they usually are worth a thousand words. These charts could be used in addition to the technical writing.

9. Do you prefer to receive shorter 'Summary' disclosures, with additional information available online or upon request?
No, I like the more detailed reports.

10. Should fund disclosures be more personalized? For example, should disclosures show the amount of fees you paid or your actual investment returns? If so, how?
Good idea on fee expense breakdown. Your annual report could break down your actual expenses over the year.

The disclosure statements would be very hard to personalize.

CONTENT

11. Do fund disclosures make the fund's strategies and the level of risk clear? How can funds improve these disclosures? Would a risk rating, such as a numerical or graphical measure of risk, be helpful?
Yes, I have noticed that most funds are increasing usage of options and other insurance techniques to reduce volatility in their returns. A system of numerical risk rating would be useful to measure the increase or decrease in risk for these strategies.

12. Fund fees and expenses can significantly affect a fund's investment returns over time. Do you think funds clearly disclose their fees and expenses? How could funds improve the disclosure of fees and expenses? Would a comparison of your funds fees against other funds fees help?
Yes, a better comparison of fund fee's and relative market risk could be very useful between similar fund strategies.

13. Do you consider the past performance of a fund when making an investment decision? How could we improve the presentation of performance information?
Past performance is always a factor in fund analysis.

FINAL THOUGHTS

14. Aside from this questionnaire, are there other ways the SEC can engage with investors, like you, on key topics? Is there anything else you would like to tell us?
Areas of concern for individual investors are: Dark pools, Computerized high speed trading, No availability to intuitional buy side analysis.

There needs to be more choice in brokerage sweep money market or banking accounts. Some brokers are forcing their clients to go into banking sweep accounts which do not offer a reasonable interest rate