In a letter to Securities and Exchange Commission (SEC) Secretary Brent J. Fields, CFA highlights the results of a recently published RAND Corporation report on investor testing of the proposed Customer Relationship Summary (Form CRS). The inescapable conclusion from the RAND Study is that, as currently conceived, the CRS does not support informed investor decision-making.

The RAND Study, like the previous testing CFA was involved in with AARP and the Financial Planning Coalition, suggests that significant changes will be needed to the design, content, and language of the proposed CRS if it is to fulfill its intended regulatory function. Therefore, CFA again asks the Commission: 1) to make this report the start, not the end, of an iterative process of testing and revision needed to develop a disclosure that works as intended; and 2) to delay finalization of Reg BI until that process is completed.

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