Subject: File No. s7-12-18
From: Matt p

December 7, 2019

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 rely on the public disclosures for all investments, but find a few areas where the public information is missing or misleading. As an experienced investor for 25+ years, I would request the following:

Closed end funds and ETFs who have "managed" distributions, should be required to disclose their SEC yield like mutual funds to. Too many are overpaying their distributions ("sucker yields") to attract yield hungry investors only for them to unknowingly get their principal paid right back to them, earnings excess fees in the meantime. This yield or coverage ratio should be standard so that investors have transparency on the MOST BASIC of investor measures, how much income are they really earning? There are many abuses of this, please email me if you need a list

Given the amount of investors who need yield this issue is a very large issue which, as I speak to investors, is poorly understood. They so often tell me "I would not have bought that fund if I knew that"

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?
Yes I do and get valuable info. See above for KEY items that are missing. Thank you.

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?
They are pretty good. Thank you. There should be an SEC site that you can request data (either via a web site or via an HTML/XML request). This would allow so many investors to get the real data, without having to use 3rd parties. For example:

Request ticker:GE
2018 EBITDA
2018 EPS
2018 DIV PAID

Returns the info investors need IN this day of tech, that should be easy to build and add so much value to investors to educate themselves

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 for some of my investments and do my own investing for others. Yes, my investment advisor does a good job of using the SEC disclosures.

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?
Website

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?
Email or web, no video or USPS mail please.

7. How can the SEC better use technology and communication tools to help investors focus on important fund information?
See my answer to #3.

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?
NO it's good.

9. Do you prefer to receive shorter 'Summary' disclosures, with additional information available online or upon request?
That sounds good

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?
That sounds great.

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?
An SEC volatilty measure would be nice but too hard to implement probably. As noted in my first answer, the biggest gap I see is people falling for phantom yields.

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?
the fee disclosures are fine.

13. Do you consider the past performance of a fund when making an investment decision? How could we improve the presentation of performance information?
I think it's fine.

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?
This page was very helpful in allowing me to express my views on a number of topics.