Subject: File No. S7-21-19
From: Miles Brooks

November 28, 2019

INVESTMENT ADVISER MARKETING FEEDBACK FORM

1. Have you ever hired, or considered hiring, an investment adviser? Because investment advisers are the subject of this proposed rulemaking, please focus your responses in this questionnaire on investment advisers rather than brokers. : Yes

2. Have you viewed any investment adviser advertisements? For example, have you looked at an advisers website or a presentation? : Yes

3. Have you looked at an advisers past performance results when considering hiring an investment adviser?
Yes

If yes, did the performance results affect your decision to hire an investment adviser?
Yes

4. Have you ever specifically requested past performance results from the investment adviser? : No

5. If you have viewed an advisers past performance results, have you discussed them with the adviser? : No

6. If you have viewed an advisers past performance results, did you believe that those past performance results would predict the future performance that the adviser could achieve for you? : Yes

7. How important is it to know the following information when reviewing the past performance results of an adviser?

Performance results minus fees and expenses (i.e., net performance) : Very Important

A schedule of the specific fees and expenses deducted to calculate net performance : Important

Performance results for one-, five-, and ten-year periods : Very Important

Other information (if any, please describe) :

8. Have you reviewed hypothetical performance results that demonstrated how an investment strategy could have or would have worked?
No

9. Have you reviewed targeted performance returns or projected performance returns?
Yes

If yes, did you discuss with the adviser the underlying assumptions on which those targets or projections were based?
Yes

10. Would other peoples opinions of the adviser (e.g., testimonials by advisory clients, and endorsements by non-clients), or an advisers rating by a third-party (e.g., Rated B+ by Adviser Reports) help you choose an investment adviser? : No

11. How important is it to know the following information when considering a testimonial, endorsement, or rating of an adviser?

Whether the person giving the testimonial or endorsement is a current client : Not Important

Whether the adviser pays the person giving the testimonial, endorsement, or the rating : Not Important

How recent the rating is, and the period of time it covers : Not Important

Other information (if any, please describe) : Testimonials are not persuasive. Ratings from third party sites (with comments) are useful.

12. What other information do you think would make the advertisements not misleading?
Don't show hypothetical performance. Limit past performance to a a near identical investment strategy.

13. Has a paid salesperson (a solicitor) ever referred you to an investment adviser? : No

14. Would it affect your decision to hire an investment adviser if you knew that the adviser paid a salesperson to refer you to the adviser? : No

15. How important is it to know the following information about a paid salespersons referral?

Amount paid to the solicitor for referring you to the adviser : Don't Know

Whether there will be any additional cost to you: Don't Know

The solicitors relationship to the adviser : Don't Know

Whether the solicitor has been disciplined for financial-related misconduct : Don't Know

Other information (if any, please describe) : Aren't all advertisements and referrals provided for compensation or some other quid pro quo.