ABOUT THIS REPORT AND DISCLAIMER

Agency decision

Ask Donna

What actually matters in this document.

Text

FISCAL YEAR 2024

Report on

Activities

ABOUT THIS REPORT AND DISCLAIMER

Section 4(g)(6) of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78d(g)(6), requires the

Investor Advocate to file two reports per year with the Committee on Banking, Housing, and Urban Affairs

of the Senate and the Committee on Financial Services of the House of Representatives.1 The two reports

are the mid-year Report on Objectives covering the forthcoming Fiscal Year and the end-of-year Report on

Activities covering the preceding Fiscal Year.

A Report on Objectives is due no later than June 30 of each year, and its purpose is to set forth the objectives

of the Investor Advocate for the following Fiscal Year.2 A Report on Activities is due no later than December

31 of each year.3 The Report on Activities describes the activities of the Investor Advocate during the

immediately preceding Fiscal Year.

Disclaimer: Pursuant to Exchange Act Section 4(g)(6)(B)(iii), 15 U.S.C. § 78d(g)(6)(B)(iii), this Report on

Activities is provided directly to Congress without any prior review or comment from the Commission,

any Commissioner, any other officer or employee of the Commission outside of the Office of the Investor

Advocate or the Office of Management and Budget. This Report on Activities expresses solely the views of

the Investor Advocate. It does not necessarily reflect the views of the Commission, the Commissioners, or

staff of the Commission, and the Commission disclaims responsibility for this Report on Activities and all

analyses, findings, and conclusions contained herein.

CONTENTS

MESSAGE FROM THE INVESTOR ADVOCATE. . . . . . . . . . . . . . . . . . . . . . . . . 1

FISCAL YEAR 2024 SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

INVESTOR ENGAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Investor Engagement Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

SEC and External Collaboration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

FY 2024 By the Numbers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Interagency Securities Council. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Looking Ahead. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

ADVOCACY FOR INVESTORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Problems Encountered by Investors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

RESEARCH AND INVESTOR TESTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

A New Survey Panel to Improve our Understanding of

Investor Behavior and Decision Making. . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Investor Testing on Mutual Fund Fee Meters. . . . . . . . . . . . . . . . . . . . . . . . . 22

Research Examining Time Horizons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

MESSAGE FROM THE OMBUDS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

ENDNOTES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

REPORT ON ACTIVITIES: FISCAL YEAR 2024

iii

“

We renew our commitment to listen

to investors, to amplify their experiences,

to address their concerns, and to further

improve the value of our contributions to

work of the Commission.”

MESSAGE FROM THE

INVESTOR ADVOCATE

he end of the 2024 fiscal year marks the

conclusion of the tenth year of service

for the Office of the Investor Advocate.

We noted in our June 2024 Report

to Congress that as the Office enters our second

decade of service to the investing public, we renew

our commitment to listen to investors, to amplify

their experiences, to address their concerns, and to

further improve the value of our contributions to

the work of the Commission.

We value that investors may want and need

different outcomes from their investment strategies,

and we strive to understand and elevate the

diversity of investment perspectives to encourage

policy making that more effectively serves the needs

of investors.

This Office has for many years dedicated resources

to conduct and publish groundbreaking research

focused on investors. To mark our tenth year

of service and to renew our commitment to

generate trusted, useful, and insightful data, in

2024 the Office launched a program of quarterly,

longitudinal surveys of investors. The Thoughtful

Households Relating InVesting Experiences

(THRIVE) Panel is a nationally representative

survey that can facilitate frequent, direct survey

research to provide timely data on investmentrelated topics, and investor testing projects

to inform policymaking or long-run research

priorities. As detailed in this report, THRIVE

was established to increase the cost-effectiveness,

timeliness, and utility of the data collection efforts

of this Office. The initiative has already yielded

promising results, and we are confident that the

value it can provide the Commission and the public

will continue to grow.

This Report on Activities

also continues our focus

on investment fraud.

In our June report, we

spotlighted an explosion

in fraud complaints.

Fraud incidents continue

to grow this year at

an alarming pace, as

reported by the Office

of the Ombuds, as well

as numerous regulators

and law enforcement agencies. The Federal

Trade Commission has reported that that

overall losses due to fraud in 2023, adjusted for

underreporting, was $158.3 billion.4 Investment

fraud is increasingly a big part of that number.

According to the United States Department of

the Treasury’s 2024 National Money Laundering

Risk Assessment, investment schemes have

surpassed business email compromise as the

highest aggregate reported dollar loss to victims.5

The Ombuds’ Report describes in detail what

REPORT ON ACTIVITIES: FISCAL YEAR 2024

has emerged as a sadly prevalent pattern of

financial deceit and devastation, as learned

from the victims who contact our Office for

assistance. We strongly encourage the greatest

possible coordination among regulators and law

enforcement to curb and cure the impacts on

not only individual victims, but also the victims’

families and communities who also pay a price

for fraud.

Finally, on behalf of the Office of the Investor

Advocate and the Office of the Ombuds, I would

like to express the deepest gratitude for the service

that Ombuds Stacy Puente has given to countless

retail investors in her time with this office. At

the end of the year, Ombuds Puente will step

down from her role, which she has served with

empathy, generosity, and intelligence. While her

dedication and leadership will be missed, her

commitment to serve the public—which everyone

shares—will continue.

I am pleased to submit this Report on Activities for

Fiscal Year 2024 on behalf of the Office of the

Investor Advocate, and I welcome any questions

from Members of Congress.

Respectfully Submitted,

CRISTINA BEGOÑA MARTIN FIRVIDA

Investor Advocate

O F F I C E O F T H E I N V E S T O R A D V O C AT E

FISCAL YEAR 2024

SUMMARY

112

DATA

COLLECTION

ACTIVITIES completed

involving over

ENGAGEMENT

ACTIVITIES

55,000

2,772

INDIVIDUAL INVESTOR

CONTACTS

INVESTOR SUBMISSIONS

to the Ombuds

193

RULEMAKINGS and SRO FILINGS

reviewed

REPORT ON ACTIVITIES: FISCAL YEAR 2024

INVESTOR ENGAGEMENT

he Office of the Investor Advocate

(OIAD) is statutorily mandated to assist

retail investors, identify problems that

investors may have, analyze the potential

impacts on investors of rules or regulations, and

make proposals to the Commission to promote the

interests of investors.6

Nations’ communities, investors with disabilities,

and investors with varying levels of exposure

to capital markets. The Office also solicits and

encourages input from stakeholders with a range of

epistemological perspectives and values.

One of the primary ways in which OIAD collects

this information and sustains a focus on investors

is through ongoing investor engagement activities7,

which directly support the statutory mandate and

help amplify the voices of investors.

Understand investor experiences and

perspectives regarding products, practices,

regulations, rulemakings, and the markets, and

communicate them in a decision-useful context

for Commission leaders and staff; and

§ Advocate for investors’ interests in the

regulatory and rulemaking environments in a

manner consistent with the Office’s statutory

mission.

INVESTOR ENGAGEMENT ACTIVITIES

The Office actively seeks input from a broad range

and variety of investors—including individual retail

investors, smaller and regional investor groups,

non-profits and consumer groups, academics and

researchers, public and private pension funds, and

other small and large money managers—as well as

regulatory and law enforcement counterparts.8

Retail investors, and their unique perspectives,

are particularly important to OIAD. We place

special emphasis on individuals and groups whose

views and needs may be less frequently heard,

including those who do not routinely travel to

Washington, DC to lobby government leaders, or

who do not regularly submit comment letters to the

Commission. Among those whom OIAD especially

seeks to hear from are older investors, new

investors, veterans and military spouses, affinityconnected investors, investors from historically

underserved, rural, or Native American/First

O F F I C E O F T H E I N V E S T O R A D V O C AT E

The goals for investor engagement are twofold:

This year, the Office expanded engagement

opportunities for retail investors to share their

experiences directly with Commission leadership

FIGURE 1. Number of Engagements

142

112

FY 2020 FY 2021 FY 2022 FY 2023 FY 2024

and staff, meeting with a broad array of investors

and investor representatives to gain from their

perspectives and inform policy, and identifying and

advocating for the trends, issues, and policies that

investors consider to be important. By leveraging

virtual and remote conferencing capabilities in a

remote-first posture, in addition to the numerous

in-person activities traditionally performed, OIAD

was able to expand the available catchment area

and welcome a number of new investors and

related groups to share their experiences with the

Investor Advocate.9

One area in which OIAD further matured this

year was to increase data-driven decision-support

across our portfolio, which provided decision

makers with useful and evidence-based investor

preferences, trends, and capabilities. OIAD has the

unique ability to identify, answer, evaluate, and

operationalize the questions of:

What do we learn from investors?

§ What do we do with that information?

OIAD does this, in part, by partnering with

other Divisions and Offices to hear directly from

investors regarding the impact that potential rules

and regulations have on investors and identify

problems that investors may have with products

or services. The goal is to further institutionalize

stakeholder (i.e. investor) input into all stages of the

Commission’s operations.

SEC AND EXTERNAL COLLABORATION

The Office further enhanced available engagement

opportunities with other SEC Divisions and

Offices, federal departments, state agencies, and

law enforcement partners—so that they could hear

directly from investors how the Commission, and

the government, can best serve them. This included:

Divisions and Offices

– The Office expanded opportunities for

investors to communicate their perspectives

directly with the Divisions. For example,

during FY 2024, OIAD organized numerous

investor engagement activities with Division

and Office Directors, so they could hear

investor commentary first-hand—including

providing input on the Division of

Examinations Exam Priorities for Fiscal

Year 2025.10

Federal Departments and Agencies

– In addition to the SEC, other federal

departments and agencies are constantly

working to protect the financial markets,

products, and consumers. As part of the

Office’s regular course of business, we often

communicate and partner with federal

agencies to support the larger investor

advocacy mission, or to obtain diverse

investor and stakeholder feedback consistent

with our statutory mission. For example, the

OIAD Investor Engagement Manager leads a

Working Group related to Online Confidence

Scams for the Commodity Futures Trading

Commission (CFTC).

State Agencies

– State Securities Regulators play a critical part

in the regulatory and investor protection

mosaic, and the Office continued to enhance

the already strong connections with the

North American Securities Administrators

Association (NASAA) and individual state

regulators. A recent example was in March

2024, the Office led the SEC-NASAA-Georgia

Secretary of State Joint Public Roundtables

in Georgia.11 This event, which took place

over two days at two different colleges in

northern Georgia, was an opportunity to

hear directly from investors and the public on

topics important to them and was attended by

Commissioner Hester Peirce, the Director of

REPORT ON ACTIVITIES: FISCAL YEAR 2024

FIGURE 2. Phases of Investor Engagement

PHASE 1

PHASE 2

PHASE 3

PHASE 4

PHASE 5

Active listening

Research and

data analysis

Collaboration and

partnerships

Decision-useful

feedback to SEC

leaders

Integration into

SEC Policies and

Practices

the Division of Enforcement, and the Deputy

Director of the Division of Examinations,

amongst other Commission Leaders. The

event was co-hosted with NASAA and the

Georgia Secretary of State, and webcast via

sec.gov.

Law Enforcement Partners

– As part of OIAD’s commitment to investors,

understanding the growth in investment

frauds is of paramount concern. To enhance

the Office’s ability to mitigate problems

and promote the interests of investors, the

Division of Enforcement has launched the

Interagency Securities Council12 (ISC), with

OIAD’s conceptualization and support. The

ISC convenes recurring meetings between law

enforcement and regulators at the federal,

state, and local levels. Additional details

are described in the Interagency Securities

Council section below.

FY 2024 BY THE NUMBERS

OIAD hosted or substantially contributed to over

110 engagements in 2024, with the cornerstone

event—the SEC-NASAA-Georgia Secretary of State

Joint Public Roundtables—occurring in March

2024 in Dahlonega at the University of North

Georgia and at Dalton State College in Dalton,

O F F I C E O F T H E I N V E S T O R A D V O C AT E

GA. At the roundtables, hundreds of investors,

advocates, investigators, and regulators shared

their experiences with investments, policy and

regulation, securities fraud, and engaged with the

Chair and Commissioners, Division and Office

directors, and senior staff related to identifying

fraud and avoiding suspicious investments.

INTERAGENCY SECURITIES COUNCIL

The Interagency Securities Council (“ISC”)13 is a

joint task force that invites federal, state, and local

regulatory and law enforcement professionals to

meet quarterly to discuss the latest in scams, trends,

frauds, and mitigation strategies, and provides

briefings on emerging and complex topics.

The ISC’s objective is to strengthen the cohesion

between federal, state, and local agencies, enhance

opportunities to collaborate on cases to protect

investors, provide insight and guidance across the

ecosystem for investigators who may not frequently

operate in the securities space, and creates a

forum for unified efforts in combating financial

fraud. Chaired by the Director of the Division

of Enforcement, the OIAD Investor Engagement

Manager envisioned, developed, and leads the

SEC’s efforts on the Council.

The ISC is limited to law enforcement and

regulatory agencies, and now includes nearly

2,000 representatives from more than 250

departments and agencies14, including federal

financial and law enforcement agencies, state

offices of attorneys general and state police, state

securities regulators, and local police departments

and sheriff’s offices. Members participate in

discussions with experts on emerging threats, hear

from investigators conducting and supervising

investigations, and explore case study examples

of agencies employing innovative approaches to

combat financial fraud. The ISC also serves as

an opportunity to connect and share information

with the larger law enforcement community that

less frequently deals with securities law violations,

such as police/sheriff departments and tribal- and

military-community law enforcement.

In FY 2024, the ISC conducted meetings and

specialized briefings with other agencies, such as

a briefing on the use of deepfakes and artificial

intelligence in financial frauds with the SEC’s

Event and Emerging Risks Team, the FBI’s

Complex Financial Crimes unit, and the Central

Intelligence Agency.

FIGURE 3. Investor Groups Represented

Retail

Investors

Financial Industry

Representatives

Legal

Representatives

OIAD

Engagement

Students and Young

Professionals

Pension Plans and

Public Retirement

Systems

Businesses and

Capital Seekers

Academic and

Advocacy Groups

Institutional

Investors

REPORT ON ACTIVITIES: FISCAL YEAR 2024

DIVISIONS AND OFFICES. Investor Roundtable

Atlanta Regional Office Director Nekia Hackworth Jones and then Division of Enforcement Director Gurbir

Grewal at the Joint Investor Roundtables at the University of North Georgia and Dalton State College

LOOKING AHEAD

In FY 2025, OIAD operations will remain robust;

with plans to continue engaging directly with retail

investors through investor-focused meetings, events,

activities, and roundtables, and by continuing to

partner with other federal, state, and local agencies

on issues relating to retail investors.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

Through these, and additional activities and

strategies, OIAD will continue to include investor

voices from the whole community in policy,

practice, and advocacy.

ADVOCACY FOR INVESTORS

his section of our annual Report on

Activities describes a selection of our

policy activities on behalf of investors

for the period from October 1, 2023

through September 30, 2024 (the Reporting

Period).

below summarizes some of the other serious

problems that investors have encountered during

Fiscal Year 2024, based on our consultation with

sources both within and outside the Commission.

PROBLEMS ENCOUNTERED BY

INVESTORS

Pursuant to Exchange Act Section 4(g)(6)(B)(III),

we are required to provide a summary of the most

serious problems encountered by investors during

the prior fiscal year. In addition, the illustration

Each of the products and practices listed below

represents an area of concern for investors during

the Reporting Period. OIAD communicates

regularly with various Divisions and Offices within

the Commission, including with the Division of

Enforcement, the Division of Examinations, and

the Office of Investor Education and Advocacy

(OIEA), among others, to gain awareness of the

FIGURE 4. Lists of Certain Problems Encountered by Investors During Fiscal Year 2024

SEC15

• Relationship Investment Scams

• Generation of excitement around

emerging AI technology and

• Exchange-Traded Products (ETPs)

deploying bots

Providing Access to Ether and Bitcoin

•

Advertisements of certificate of

• Fake Form 4 Filings

deposit accounts with supposed

• Accidental Text Messages on Social

high-yields

Media Platforms

• Leverage and Inverse ETFs

NASAA16

Reported

potentially

problematic

products or

practices

• Digital Asset Frauds

• "Pig Butchering" Schemes

• Social Media & Internet Schemes

FINRA17

• Phantom Riches

• Social Consensus

• Source Credibility

• Scarcity

• Reciprocity

PCAOB18

• Proof of Reserve Assertions

• High Audit Deficiency Rates

• Recurring Quality Control Deficiencies

REPORT ON ACTIVITIES: FISCAL YEAR 2024

problematic products and practices that such

Divisions and Offices may discern in the course

of their work. The Office also maintains regular

communications with other regulators, such as

Financial Industry Regulatory Authority (FINRA),

NASAA, Public Company Accounting Oversight

Board (PCAOB), and the Municipal Securities

Rulemaking Board (MSRB) to maintain visibility

into problematic products and practices that those

regulators have confronted in their day-to-day

responsibilities during the reporting period.

Focus on Complex Investment Fraud

Public trust in the integrity of the securities markets

is necessary for our capital markets to thrive.

Investors are not required, however, to take a leap

of faith by allocating their savings to the capital

markets without a basis for trust in those markets.

For decades, regulatory examination regarding,

and enforcement of, our federal and state securities

laws and rules have worked to instill that trust.

This financial regulatory structure is designed to

help protect investors and lower the cost of capital

raising, benefitting market participants and the U.S.

economy as a whole.

Unfortunately, investors who experience

investment fraud, manipulation, or abuse often

lose twice. First, having trusted a bad actor, such

as a dishonest financial representative or an

unregistered adviser, these investors may suffer the

loss of some or all of their hard-earned savings.

Second, they may experience a loss of confidence

in the securities markets. With personal investment

decisions becoming much more important to

the well-being of Americans looking to save

for retirement, the purchase of a home, or their

children’s education, the loss of confidence in the

securities markets can compound the damage

already inflicted upon them by an unscrupulous

financial representative or a criminal pretending

to be a legitimate adviser. By retreating from the

O F F I C E O F T H E I N V E S T O R A D V O C AT E

securities markets, investors who stow their money

under the proverbial mattress may keep their funds

safe from con artists, but those funds will not grow

in value and, in fact, will lose buying power over

time due to inflation.

Because of the foregoing considerations, our Office

has focused on the problem of complex investment

fraud over the last year and will continue to do

so for the foreseeable future as these fraudulent

schemes proliferate and gain momentum. Directly

below, we discuss the highlights from our ongoing

review of relevant news and reports, insights into

new trends and growing complexity in the markets,

and how our Office expects to address these

developments. In the Ombuds’ Report, a deeper

examination is provided of how investment fraud

schemes currently threaten investors.

Investment Fraud Trends

As noted in our last report to Congress, investment

fraud continues to beleaguer contemporary

investors, securities markets, and law enforcement.

While investment fraud itself is not new, the

methods used to commit such fraud constantly

evolve, and as noted below in the Ombuds’ Report,

our Office has experienced a recent surge in fraud

complaints. Multiple government agencies, here

and abroad, have recently also reported an increase

in fraud generally.

A common element in these reports, including

complaints to our Office, is the role advanced

technologies play in facilitating complex fraud. It

is important to acknowledge that technological

advancements are opening doors for new

populations of investors to participate in the

markets and build wealth. Additionally, innovative

new financial products are allowing retail investors

to access complex investment strategies previously

reserved for sophisticated institutional investors.

For some individuals who wish to invest in

innovative products, the features of developing

or emerging technologies may themselves be the

impetus for becoming an investor. For instance,

“the use of digital ledger technology (DLT) may

have the potential to foster financial innovation,

increase efficiencies, and improve access to

financial products, services, and activities.”19

These same advancements, however, enable

criminals to deepen the pool of potential fraud

victims. Evolving technology has made deception

more challenging for investors to recognize.

Technological advancements further provide

criminals with the tools to communicate more

effectively, scale their schemes more rapidly

than before, and conclude their frauds through

effectively unrecoverable payments. Alarmingly,

investment fraud enabled by technology is

accelerating at a scale and complexity not

previously possible to accomplish even a year ago.

Given this new reality, it may be challenging to

see through scams, especially when legitimate

investment products and services have become

increasingly complex and harder to understand.

If it is difficult for investors to digest lawful, yet

complicated disclosures, the resulting opaqueness

can widen the window of opportunity for criminal

behavior to occur.

Technology also permits fraudulent schemes to

proliferate much more rapidly than in the past.

As the Commission noted in a recent rulemaking

proposal, “due to the scalability of [predictive data

analytics (PDA)] technologies and the potential for

firms to reach a broad audience at a rapid speed . . .

any resulting conflicts of interest could cause harm

to investors in a more pronounced fashion and on a

broader scale than previously possible.”20 Although

the Commission’s proposal was focused on the use

of PDA technologies by firms acting lawfully and in

good faith, its statements about the rapid scalability

of harm associated with advanced technologies is

relevant to bad actors as well.

While we acknowledge that investing in crypto

assets may represent an entry point into investing

for many investors, the Ombuds’ Report below

details how evolving technologies, such as cryptorelated payments and social media has led to an

increase in fraudulent schemes reported to the

Ombuds. Beyond the Ombuds and within the SEC,

OIEA has reported a similar increase in the number

of complaints related to crypto-related investments.

In its annual list of Ten Most Common Complaints,

OIEA reported receiving 1,075 in fiscal year

2020,21 4,599 in fiscal year 2021, 5,040 in fiscal

year 2022, and 5,357 crypto-related complaints in

fiscal year 2023.22 OIEA has published an Investor

Alert warning that fraudsters are targeting victims

by offering crypto related investments.23 While

some fraud is committed using schemes wherein

the underlying crypto-related investment itself is

illegitimate, the vast majority of these fraudsters

are simply using crypto-related payments as an

enabling tool. Similarly, the SEC’s Office of the

Inspector General has recently highlighted the

challenges in protecting investors from crypto-asset

related fraud.24

The SEC’s Investor Advisory Committee has also

expressed concern about digital-asset based fraud,

and the semi-anonymous and borderless nature of

crypto transactions that make them well-suited for

various illegal activities such as money-laundering

and tax evasion.25

Beyond the SEC, other regulators are also reporting

a significant increase in crypto-related complaints.

For instance, in its Cryptocurrency Fraud Report

for 2023, the Federal Bureau of Investigations

(FBI) Internet Crime Complaint Center (IC3)

reported receiving 69,468 complaints from the

public regarding cyber-enabled crime and financial

REPORT ON ACTIVITIES: FISCAL YEAR 2024

fraud involving the use of crypto, with over

$5.6 billion in reported losses, constituting a 45

percent increase in reported losses since 2022.

Losses from cryptocurrency-related investment

fraud schemes reported to IC3 rose $2.57 billion

in 2022 to $3.96 billion in 2023, an increase of

53%. Many individuals reported accumulating

massive debt to cover losses from these fraudulent

investments. Additionally, of the complaints

submitted to the FBI IC3, the exploitation of crypto

was most pervasive in investment scams, where

losses accounted for 71 percent of all losses related

to crypto.26

Similarly, the Federal Trade Commission (FTC)

reported an increase in the amount that consumers

reported losing to fraud, $10 billion in overall

losses in 2023. The FTC also reported an increase

in the amount that consumers lost to investment

scams, with a 21 percent increase from 2022

to 2023, and a reported loss of $4.6 billion in

2023. 27 The second highest reported loss amount

came from imposter scams, with losses of nearly

$2.7 billion reported. Moreover, in its 2024

Report on Protecting Older Consumers, the FTC

acknowledged that underreporting results in an

incomplete picture of the scale of the problem.

The FTC estimated that overall losses due to

fraud in 2023, adjusted for underreporting, was

“$158.3 billion or $23.7 billion for consumers of

all ages and $61.5 billion or $7.1 billion for older

adults.”28 The FTC explained that those estimates

are based on two different assumptions about the

degree of underreporting for high dollar losses.

Separate from crypto-related investment fraud,

the SEC’s OIEA, NASAA, and FINRA have all

warned investors that bad actors are using the

growing popularity and complexity of AI to lure

victims into scams.29 The FBI has noted that “AI

provides augmented and enhanced capabilities to

O F F I C E O F T H E I N V E S T O R A D V O C AT E

schemes that attackers already use and increases

cyber-attack speed, scale, and automation.”30 The

National Security Agency (NSA), the FBI, and the

Cybersecurity and Infrastructure Security Agency

(CISA) warn that “[m]alicious actors, many of

them likely cyber criminals, often use multiple

types of manipulated media in social engineering

campaigns for financial gain. These may include

impersonating key leaders or financial officers

and operating over various mediums using

manipulated audio, video, or text, to illegitimately

authorize the disbursement of funds to accounts

belonging to the malicious actor.”31 Fraudsters

also may use AI technology to produce realistic

looking websites or marketing materials to

promote investment scams, or deepfakes to

deceive investors.32

On a global level, as INTERPOL notes in its recent

Global Financial Fraud Assessment: “Within

financial fraud, technology has emerged as the

key enabling factor for criminal groups . . . The

use of artificial intelligence, large language models

and cryptocurrencies combined with phishing-and

ransomware-as-a-service business models have

resulted in more sophisticated and professional

fraud campaigns without the need for advanced

technical skills, and at relatively little cost.”33

Additionally, the World Economic Forum, in

its The Global Risks Report 2024, reports that

“easy-to-use interfaces to large-scale artificial

intelligence models have already enabled an

explosion in falsified information and so-called

‘synthetic’ content, from sophisticated voice cloning

to counterfeit websites.” 34 The World Economic

Forum also ranks AI-generated “misinformation

and disinformation” as the second highest risk

“likely to present a material crisis on a global scale

in 2024.”35

As the use of crypto payments in the global

financial system continues to increase, our Office

will continue to pay close attention to the issues

surrounding digital asset-based fraud and the

technologies that are used to perpetrate those

frauds. Our Office will also continue to work with

our SEC colleagues to encourage that disclosures

related to complex investment products and

services are presented in a manner that retail

investors can more easily digest. Conducting

investor testing on proposed financial disclosures

and continuing to strive for greater comprehension

of those disclosures, may help retail investors better

understand their legitimate investment choices,

potentially reducing the opaqueness that criminals

currently exploit to their advantage.

More generally, complex investment fraud will

remain a key area of focus of our Office moving

forward, given the billions in investor losses. We

will maintain our outreach efforts to investors

(particularly retail investors), financial regulators,

market participants, and other stakeholders in

an effort to better evaluate the myriad issues

associated with investment fraud today. We will

continue to explore ways to deter investment

fraud and financial exploitation from occurring in

the first place, as well as possible approaches to

assisting the victims of fraudulent schemes more

effectively after the fraud has occurred. We will

continue to evaluate pending legislative proposals

in Congress that relate to investment fraud

and analyze their potential impact on investors

and consider whether there may be a need for

additional resources, or ways to deploy existing

resources more productively, in countering

investment fraud. Last, we strongly encourage

the greatest possible collaboration among law

enforcement agencies to combat investment fraud.

REPORT ON ACTIVITIES: FISCAL YEAR 2024

RESEARCH AND

INVESTOR TESTING

he Office of Investor Research (OIR) is

a multidisciplinary research group that

serves investors by identifying, analyzing,

and addressing investors’ concerns.

Through its role as part of the OIAD, OIR’s

research on investor behavior and decision making

provides an empirical basis for policy decisions,

OIAD priorities, and SEC activities, ultimately

helping investors succeed.

OIR provides insights on how investors and

other stakeholders interact with the investment

marketplace and how they are affected by SEC

policy. OIR enables OIAD and the Commission to

more thoroughly:

1. “Identify areas in which investors would

benefit from changes in the regulations of the

Commission or the rules of self-regulatory

organizations;”36

2. Test potential policies before adoption,

identifying areas in which investors would

benefit from changes in regulation and allowing

the Commission to “analyze the potential

impact on investors of proposed regulations

of the Commission. . . proposed rules of

self-regulatory organizations . . . and . . . to the

extent practicable, propose to the Commission

changes in the regulations;”37

3. Conduct “retrospective analysis of rules”

to help ensure that policies are working as

intended;38

4. Study investor behavior and outcomes to

“identify problems that investors have with

financial service providers and investment

products;”39 and

O F F I C E O F T H E I N V E S T O R A D V O C AT E

5. Generate evidence of organizational

management and efficacy, particularly

regarding “outcome” performance indicators.

To accomplish these aims, OIR draws on deep staff

expertise from fields including economics, finance,

psychology, and judgment and decision-making.

OIR staff are recognized experts in these fields who

have published over 60 peer-reviewed journal

articles or book chapters and have presented

research at more than 100 conferences during their

careers. Despite having a team of only five full-time

Ph.D. researchers, OIR’s team provides the SEC

with expertise across broad subject matter and

methodological areas.

Through the Policy-Oriented Stakeholder and

Investor Testing for Innovative and Effective

Regulation (POSITIER) initiative,40 OIR’s founding

architecture, OIR uses its expertise for long-term

research projects of fundamental importance and

applied, collaborative projects with SEC teams

to inform policymaking. In these endeavors, OIR

designs bespoke research using a variety of research

methods, drawing on extensive experience with

econometric modeling, natural language processing,

text analysis, experimental design, survey methods,

survey sampling, qualitative interviews, and other

state-of-the-art research methods. Further, projects

are designed to be rapid and cost-effective.

FY 2024 was OIR’s most productive year in terms

of data collection: we completed 21 distinct survey

projects and three qualitative studies. Adding this

work to our past efforts, OIR has conducted a total

of 71 surveys or experiments, 18 qualitative

studies, and several analyses of market data over its

lifetime (since June 2017). Multiple rulemaking

documents cite our research, thereby impacting the

investing public. Additionally, we engage in

thought leadership to policy and academic

communities, encouraging others to serve investor

interests through advocacy, research, or direct

outreach.

Qualitative

Quantitative

Over

more investor

contacts than the previous year

In FY 2024, highlights of our research group

included:

Establishment of the nationally representative

THRIVE survey panel to help OIR contact

investors in a timely, cost-effective manner.

In the first quarter of FY 2024, we launched

the nationally representative Thoughtful

Households Relating InVesting Experiences

(THRIVE) Panel to facilitate frequent, direct

survey outreach with the public. THRIVE is

a platform to help OIR conduct surveys that

provide timely data on investment-related

topics, and investor testing projects to inform

SEC rulemaking and long-run research

priorities. THRIVE was established to increase

the efficiency of OIR’s data collection efforts,

an initiative that has already yielded results. In

part thanks to THRIVE, we had 57,855 total

investor contacts in FY 2024, representing more

than 4 times the number of investor contacts

in FY 2023.

A rigorous research project on registered

investment company fee meters to affect a

potential rulemaking proposal. In conjunction

with the SEC’s Division of Investment

Management, OIR conducted research

examining graphical displays of mutual fund

expense ratios, known as “fee meters.” This

project built on OIR’s published research,

discussed in the OIAD’s FY 2022 Report on

Activities,41 demonstrating that prototype fee

meters could help investors viewing a set of

index funds allocate a higher proportion of their

hypothetical investment balance to lower-cost

funds, thereby avoiding unnecessary fees. In

the current work, we examined the effects of

a fee meter when investors view a single fund,

measuring potential impacts on knowledge

of relative costs, evaluations of the fund, and

interest in seeing an alternative mutual fund.

This project highlights the value of long-run,

iterative investor testing projects, with research

leading to better-informed potential rulemaking

activities.

A novel research project on the measurement

of investor time horizons to understand factors

driving reported time horizons. Financial time

horizons are a key component of the financial

advice that investors receive from financial

advisers and brokers. Financial advisers and

brokers often collect an investor profile to

determine the best investment strategy for

their clients, and according to regulatory

interpretation by the SEC, the investor profile

should include questions to understand

the client’s time horizons.42 We show that

seemingly minor variation in the response

REPORT ON ACTIVITIES: FISCAL YEAR 2024

options shown on time horizon questions can

dramatically affect investors’ answers, changing

the proportion who appear to have a long-run

or short-run time horizon for their financial

goals. This project expands OIR’s research on

financial advice and raises questions about the

consistency of existing time horizon elicitations,

with likely downstream consequences for the

quality of advice investors receive.

§ Dissemination of investor-related research in

multiple communities, including through the

Boulder Summer Conference on Consumer

Financial Decision Making, the RAND

Behavioral Finance Forum, and the Current

Innovations in Probability-based Household

Internet Panel Research (CIPHER) Conference.

These discussions help increase OIR’s impact by

raising awareness of our research, generating

additional interest about investor issues among

researchers and policymakers, and identifying

areas of future research.

As always, OIR is aware that making financial

decisions and achieving financial security

remain difficult for many. We will continue

to pursue research to help the public to make

better investment decisions and avenues for OIR

to collaborate with SEC staff on high-impact

projects. We anticipate continued work on specific

research areas that would benefit from additional

attention: financial product information and

disclosure; provision of financial advice or related

communications; and investor participation,

perception, and decision-making in an evolving

economic environment. The rest of this year’s

report on investor testing presents additional details

about our highlighted research projects.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

A NEW SURVEY PANEL TO IMPROVE

OUR UNDERSTANDING OF INVESTOR

BEHAVIOR AND DECISION MAKING

In the first quarter of FY 2024, we launched

the Thoughtful Households Relating InVesting

Experiences (THRIVE) Panel. OIR established

THRIVE to facilitate frequent, direct survey

outreach with the general public.43 THRIVE is

a platform to help OIR conduct two primary

activities: surveys that provide timely empirical data

on investment-related topics, and investor testing

projects to inform SEC rulemaking and long-run

research priorities. As part of THRIVE quarterly

surveys, the same 7,500 people are invited to

answer recurring questions on investment decisions

and household events, as well as novel questions

examining contemporaneous areas of interest.

For investor testing, THRIVE respondents (or

subsamples of respondents) participate in custom

projects designed by OIR to address rulemaking

proposals or other key SEC policy needs. THRIVE

is representative of the overall US population, with

oversamples based on race and ethnicity to allow

for subgroup analysis.

Goals of THRIVE

OIR created THRIVE as a nationally representative

survey panel focused on investing and the policy

interests of OIAD and the SEC. To that end,

THRIVE surveys include content reflecting OIAD

priorities, including (1) the content, presentation,

and manner of delivery of financial product

information; (2) investor experiences related

to the provision of financial advice and related

communications; and (3) investor participation,

perception, and decision-making in an evolving

economic environment.

THRIVE addresses OIR research needs in

five important ways (Figure 5). First, a key

responsibility of OIR is to conduct investor testing

to support rulemaking. THRIVE facilitates online

surveys, allowing respondents to view realistic

sample elements of proposed disclosures, such as

new text and visuals. Second, financial market

events and policy interests can move quickly.

THRIVE is designed so that OIR’s research

can respond rapidly to time-sensitive requests,

including from the SEC and Congress. An online

standing panel allows us to identify respondents

who would be suitable to meet current research

needs and launch studies within a matter of

weeks, not months. Third, the SEC is interested

in understanding how investor behavior changes

over time. By surveying the same people over

time, we observe individual transitions (e.g., when

a non-investor becomes an investor). Fourth,

THRIVE’s panel structure—that is, returning to

the same people over time rather than surveying

new people each round—allows OIR to create and

track repeated measures over time. Fifth, THRIVE

provides a cost-effective way to meet OIR’s

research needs. Linking an individual’s responses

over time increases efficiency and reduces costs

because relevant individuals can be targeted for

surveys based on historical responses. Additionally,

stable constructs that are used in many studies can

be measured less frequently. As an example, the

RILA research described in the Report on Activities

for FY 202344 could have benefited from THRIVE,

as it would have allowed us to identify potential

respondents based on their annuity ownership

and draw on previously measured constructs such

FIGURE 5. Why did we develop THRIVE?

Investor testing to support rulemaking

Online surveys allow us to test disclosures, showing

respondents text and visuals.

Ability to respond to time-sensitive

research needs

Quick survey delivery because we have already

identified a sample suitable for many research projects.

Study within-household shocks and

changes

By surveying the same people over time, we observe

individual transitions.

Creation of metrics

By asking a repeating set of questions, we

can reliably track trends and developments.

Cost-effective

Linking responses over time increases efficiency and

reduces costs.

REPORT ON ACTIVITIES: FISCAL YEAR 2024

as financial literacy. “Sampling” (i.e., identifying

specific people to survey) typically represents

a large proportion of the total time and costs

required to field a nationally representative survey.

With THRIVE, we created a reusable sample,

mitigating many of the costs associated with survey

research.

THRIVE Builds on OIR’s Experience and

Expertise

THRIVE draws on the OIR team’s combined

research experience and expertise (Figure 6).

OIR staff have dedicated their careers to

studying financial decision making; however,

developing a panel requires additional expertise.

Over their careers, the OIR team has developed

hundreds of surveys and experiments. To develop

survey questions, OIR draws on best practices

for measuring key concepts and testing new

questions, including conducting qualitative

interviews to better understand how respondents

understand survey questions. OIR also has

experience with statistical methods, such as

development of survey weights that are used to

address any imbalances in the representativeness

of the panel (for example, those introduced

by oversamples based on race and ethnicity).

Finally, members of the OIR team have over

10 years of experience with panel management,

which provides us with expertise in all aspects

of designing and maintaining a panel, including

recruiting and retaining participants, analyzing

potential statistical biases related to drop-out,

protecting respondents’ privacy, and determining

whether participants’ responses are conditioned

by repeated surveys.

Types of Surveys

THRIVE consists of three types of surveys:

baseline surveys, quarterly surveys, and custom

investor testing surveys. Survey content is selected

and ordered to minimize respondent burden,

where possible.

There were two baseline surveys fielded in the fall

of 2023. These baseline surveys were designed

to provide an initial, thorough view of key

investor behaviors and characteristics as well as

fixed characteristics that are unlikely to change

considerably over time. Baseline survey data

provides ongoing value to the SEC by allowing

surveys to be sent specifically to individuals

with certain characteristics, ensuring future data

collection is cost-effective.

FIGURE 6. How Staff Expertise Contributes to THRIVE

OIR STAFF EXPERTISE

• Financial decision making

• Survey development

• Experimental design

• Qualitative interviewing

• Statistical weighting

• Panel management

O F F I C E O F T H E I N V E S T O R A D V O C AT E

THRIVE

Following the baseline surveys, OIR started

quarterly THRIVE surveys in January 2024. There

are two sections to each quarterly survey. The first

section contains key recurring content, including

investment behaviors in the preceding 90 days and

measures of current financial status. The second

section changes across quarters and includes

questions to provide a deeper understanding of

a given individual’s responses, or to measure

concurrent topics of interest. This latter section

can also include one-time modules to measure

relatively stable individual characteristics that

were not included in previous surveys.

In addition to baseline and quarterly surveys,

THRIVE can be used for custom investor testing

surveys. These surveys can take many forms but

may be used inform policy making, improve

research methods, or examine other areas of

long-term interest.

Who is Included in THRIVE

Most THRIVE surveys, including the quarterly

surveys, invite the same 7,500 people to respond.

Participation rates are generally high, with

approximately 6,000 people participating in each

survey. This group includes both investors and

non-investors, allowing us to monitor investor

behavior, barriers to investing, and the transition

from non-investor to investor. The THRIVE sample

also oversamples Black, Hispanic, and Asian

adults to ensure that we can accurately measure

differences in behavior across these groups.45

Figure 7 illustrates the demographic characteristics

of the THRIVE panel.

FIGURE 7. Summary of THRIVE Participant Demographic Characteristics

GENDER

FEMALE

EDUCATION

9.4% Less than high school

28.8% High school or equivalent

27.9% Some college/associates degree

MALE

50.2% 49.8%

20.2% Bachelor’s degree

13.6% Post grad study/professional degree

AGE

20%

15%

18.8%

18.3%

RACE/ETHNICITY

Asian-Pacific Islander,

8.0% non-Hispanic

18.5%

12.7% Black, non-Hispanic

14.3%

12.8%

19.9% Hispanic

12.0%

10%

5.3%

57.4% White, non-Hispanic

0.6% Other, non-Hispanic

18-24

25-34

35-44

45-54

55-64

65-74

75+

1.4% Two or more,

non-Hispanic

REPORT ON ACTIVITIES: FISCAL YEAR 2024

FIGURE 8. Recent Results from THRIVE panel

Percent of U.S. Population with

Different Investment Types

Proportion of U.S. Population

75%

50%

25%

Jan 2024

Apr 2024

Survey

Jul 2024

Brokerage Account

Retirement Account

Crypto Currency

Any Account

Proportion of U.S. Population

Last Sale of a Financial Investment

7.5%

5.0%

2.5%

0.0%

Jan.

Apr

Survey

Jul

Proportion of U.S. Population

Last Purchase of a Financial Investment

20%

15%

10%

Jan.

Today

Apr

Survey

Last 30 Days

Jul

30 to 90 Days

Figures show the proportion of the U.S.

population buying or selling in each of the

THRIVE quarterly surveys.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

Initial Lessons from THRIVE

Since launching THRIVE in October 2023,

seven surveys have been fielded on the THRIVE

panel. These surveys have contributed to

ongoing research and to our understanding of

key investment behaviors. Figure 8 illustrates

several of the measures that we are tracking each

quarter, weighted to be representative of the U.S.

population.

We find that over 60% of U.S. adults report having

a retirement account, over 35% report owning a

brokerage account, and approximately 10% report

owning crypto currency, as shown in the top panel

of figure 8. Overall, 70% report having one or

more of these financial investments. These numbers

are similar to those found in other nationally

representative surveys. The Federal Reserve’s 2022

Survey of Consumer Finance found that 54.4%

report having retirement accounts.46 The FINRA

2021 National Financial Capability Study found

that 36% have brokerage accounts.47 The Federal

Reserve’s 2023 Survey of Household and Economic

Decisionmaking found that 6.7% reporting owning

or buying cryptocurrency in the last year,48 while

Pew Research reported in 2023 that 17% had ever

owned cryptocurrency.49

Because THRIVE surveys the same people multiple

times a year, we are able to better understand

changes in ownership over time. While the overall

numbers suggest stability in overall ownership rates,

they mask underlying changes in who owns each

type of investment. As an example, over 15% of

people who report owning cryptocurrency in April

2024 do not report owning cryptocurrency three

months later, in the July 2024 quarterly survey.

There are similar numbers of people opening

new accounts, highlighting a key benefit of panel

data: the ability not only to observe levels but also

changes in ownership. Further research is needed to

understand whose ownership is changing, and the

reasons behind these shifts.

future content. For instance, we can link data on

asset ownership with major household events, or

link information on investment advice and mutual

fund knowledge to study the relationship between

financial advice and beliefs about mutual fund fees.

Another way of exploring ongoing investment

behavior is to examine purchases or sales of assets

in the last 90 days (Figure 8). In each of the surveys

shown, approximately one quarter of the U.S.

population reports purchasing a financial asset in

the last 90 days, and approximately 10% report

selling an asset in the last 90 days. The share

purchasing assets almost certainly understates

ongoing new contributions to retirement accounts

through payroll deduction. Financial asset owners

and purchasers include people from all walks of

life; THRIVE is allowing OIR to better understand

the behaviors of investors and non-investors alike.

The Future of THRIVE

THRIVE provides OIR with a valuable tool for

monitoring investor behavior and conducting

investor testing. As a custom SEC resource,

THRIVE is designed specifically to yield insights

across the agency. Partially due to efficiencies

gained by THRIVE, we had more than 4 times

the number of investor contacts in FY 2024 as

FY 2023. THRIVE provided data that contributed

to our study of fee meters, discussed further below,

and the measurement of key investor behaviors.

OIR will continue to delve into these rich data to

deepen our understanding of investor behavior and

decision making.

The value of THRIVE multiplies over time as we

conduct interesting analyses across surveys and add

THRIVE is more efficient than recruiting new

respondents from scratch; however, it requires

maintenance. Quarterly data collection means

OIR staff must engage frequently to ensure that

surveys are responsive to emerging SEC and OIAD

needs. OIR must retain specialized staff to ensure

continued quality of THRIVE, with required

expertise spanning both substantive fields and

methodological training. Ensuring that THRIVE

can continue to provide benefits to the SEC will

require sufficient funding and staffing in the years

to come.

INVESTOR TESTING ON

MUTUAL FUND FEE METERS

Mutual fund fee dispersion raises recurring

policy and academic concerns about whether

investors are paying too much for mutual funds.

Over the past several years, OIR has tested

various disclosures of mutual fund fees designed

to make consumers aware of the importance of

fees and improve their decision making about

investments. In our 2022 annual report, we

described this work, which was subsequently

published in the Journal of the Association for

Consumer Research in 2023.50 In FY 2024, we

continued this line of research through new

testing exploring the effects of a mutual fund

“fee meter.”51 The goal of a fee meter is to help

investors compare fees across funds with similar

objectives. Our testing uses no load mutual

funds, so the only fees and costs are those

reflected in the expense ratio (the percentage of

an investor’s assets under management that the

investor has to pay to the mutual fund company

annually).

REPORT ON ACTIVITIES: FISCAL YEAR 2024

Background on Price Dispersion and

Potential Benefits of Shopping

The mutual fund market is characterized by

significant price dispersion—that is, some

funds are more expensive than others—even

when accounting for differences in investment

strategy and risk. Indeed, we found that the fees

on no-load non-institutional share classes for

S&P 500 mutual funds in 2023 ranged from

0% to 1.61% per year (as shown in Figure 9),

a pattern that has been demonstrated in past

research studying historical dispersion in fees for

S&P 500 index funds.52 There is also significant

fee dispersion within and across broader sets of

mutual funds.53

It is important for investors to understand price

dispersion in the mutual fund market so that

they can make informed decisions about mutual

funds. In particular, price dispersion across a set

of funds that have a similar investment strategy

and risk profile suggests that consumers who

search the mutual fund market may find lower cost

alternatives. Especially in the case of index funds,

that seek to track the returns on an index such as

the S&P 500, lower cost alternatives can provide

investors an unambiguous financial benefit.

If the S&P 500 index rises by 10% in a given year,

a high-fee S&P 500 mutual fund (with an expense

ratio of 1.05%) would earn about 8.95% that

year, whereas a low-fee fund (with an expense

ratio of 0.14%) would earn about 9.86% that

year. In subsequent years, investors remaining in

the high-fee fund could forgo additional earnings

on the money lost to fees, meaning that differences

due to fees would compound over time. Continuing

with our example of a 1.05% expense ratio fund

and a 0.14% expense ratio fund, Figure 10 shows

the difference in returns for a $10,000 investment

over 10 years assuming an annual return of 10%.

While the difference between these two investments

is only $91 after the first year, after 10 years the

difference is nearly $2,000.

Given this background, spurring investors to search

for less expensive funds could save them significant

amounts of money. Past research conducted by

OIR54 suggests that fee meters may help consumers

choose among a group of mutual funds, but did

not explore whether providing such information

for a single fund improves consumers’ knowledge

of relative costs and helps them decide when it is

in their interest to search for a cheaper fund. The

current research addresses those gaps.

FIGURE 9. Distribution of Expense Ratios for S&P 500 Index Funds on the Market

Number of share classes

0.0%

0.5%

1.0%

1.5%

This figure shows the distribution of expense ratios for no-load, non-institutional share classes of S&P 500 index

mutual funds, with each share class included separately, as of November 2023.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

FIGURE 10. Approximate Value of a $10,000

Investment Over Time Assuming a 10%

Annual Return

FIGURE 11. Estimated and Actual Percent of

Funds that are Less Expensive

$24,444

Percent of funds

Dollars (Thousands)

$22,484

42%

0.08%

0.32%

38%

42%

Years

High fee

0.48%

0.49%

Expense ratio (fee)

Low fee

Estimated percent of funds that are less

expensive

This figure shows how the value of a $10,000

investment changes over time, assuming a constant

10% annual return. The “high fee” line portrays an

investment in a fund with an expense ratio of 1.05%.

The “low fee” line portrays an investment in a fund

with an expense ratio of 0.14%.

Actual percent of funds that are less expensive

Lesson 1. People Don’t Understand the

Relative Cost of Fees

Our research first sought to establish whether

people are aware that a given mutual fund fee is

relatively high or low. Each person viewed the

expense ratio for one of four S&P 500 index funds,

which varied in terms of their fees. Specifically,

they were shown funds with an expense ratio of

0.08%, 0.32%, 0.48%, or 0.49%. They were

then asked to estimate the percent of similar funds

that had a lower fee. Figure 11 shows the average

estimates provided by participants, as well as the

true relative costs. Across all expense ratios, people

provided similar responses. Without context,

they estimated that all four example fees were

roughly in the 40th percentile of cost. We found no

differences in response patterns by peoples’ mutual

fund ownership and knowledge of mutual fund

fees. These findings suggest that investors are not

This figure shows estimated and actual percent of

funds that are less than a given fee. For instance,

participants receiving a fund with an expense ratio

of 0.08% thought that 42% of funds were cheaper,

on average. However, only 19% of funds were

cheaper. The difference between the height of the

aqua bars and the red lines therefore shows the

mismatch between estimated and actual relative

costs. Participants, on average, underestimate the

relative cost of funds with expense ratios of 0.32%

or higher.

aware of relative costs in the mutual fund industry

and that a visual aid containing this information

may be helpful for investors.

The average errors (the difference between aqua

bars and red lines) that we see in Figure 11 suggest

that investors are most confused about relative

costs for the cheapest and most expensive funds.

Both errors are concerning. Investors who hold

relatively inexpensive funds, but are unaware of

those low costs, may be motivated to search for

an alternative, but this could be a time-consuming

activity with little financial benefit. On the other

REPORT ON ACTIVITIES: FISCAL YEAR 2024

hand, if investors have an expensive fund but do

not realize it, they are unlikely to shop around even

if shopping would financially benefit them greatly.

The finding that many investors are unaware of

fund fee dispersion can explain why some investors

hold high-cost index funds.

Lesson 2. Fee Meters Help People

Understand Relative Costs

Given peoples’ lack knowledge of the dispersion

of fees charged by mutual funds, we next designed

an experiment to see if a simple visual aid could

increase awareness of which funds were more or

less expensive. Over 4,000 people were provided

with information about a hypothetical S&P 500

mutual fund including: the objective of the fund,

fees, risk factors, and performance

People were randomly assigned to one of four

different presentations of fee information: no meter

(text only), a continuous meter, a discrete meter

that adds category boundaries to the continuous

meter, or a labeled meter that adds information

about the fees at each category boundary

(an example of the labeled meter is shown in

Figure 12). We tested these different versions of the

meter, as finding the optimal visual display requires

testing such design elements.

Middlewood Fund

Fees: 0.37%

High

0.14%

0.24%

0.36%

0.51%

This figure shows an example of a labeled fee meter

for a hypothetical S&P 500 index fund with a 0.37%

expense ratio.

On average, people that saw any fee meter were

more accurate about the relative cost of their

assigned fee than those that did not see a fee meter.

Figure 13 shows us that people viewing a fee

meter were better able to assess the relative cost

of the fund that they viewed—the gaps between

the estimate (solid yellow, gray and blue lines) and

true costs (dashed red line) were about half the size

among those seeing a meter, versus those seeing

fee information only as text (solid green line). For

instance, people viewing only text information

about fees estimated that a fund with a 1.05%

expense ratio was more expensive than 45% of

funds. With a fee meter, investors believed that fund

was more expensive than 60% of funds, which is

closer to the true value of 98%. While the meters

increased the accuracy of these estimates, the exact

characteristics of the meter (continuous, discrete,

labeled) did not have a significant effect on cost

percentile estimates.

Better informed investors will be able to make

better decisions about their investments. Fee meters,

which increase knowledge about relative costs,

have the potential to help people make investment

decisions that are right for them.

FIGURE 12. Example of a Fee Meter

Low

Participants were also randomly assigned to one of

five fee levels: 0.14%, 0.37%, 0.50%, 0.51%, and

1.05%, which covered much of the distribution

of actual costs for S&P 500 index funds as of the

time of the testing. In all meter conditions, the

fee assigned to the participant was shown at the

appropriate location along the meter.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

Lesson 3. More is Needed to Help People

Translate Knowledge about Relative

Costs into Behavior

In the case of index funds, those who believe

that their fund is relatively expensive should be

more interested in searching for a cheaper fund,

whereas those who believe their fund is relatively

inexpensive should be less interested in searching

FIGURE 13. Estimated and Actual Percent of Funds that are Less Expensive for Participants Seeing

Fee Information as Text or on a Meter

Percent of Funds

100

0.14

0.37

0.5

0.51

1.05

Expense ratio (fee)

Text

Meter

Discrete Meter

Labeled Meter

Actual Value

This figure shows estimated and actual percent of funds that are less than a given fee. The lines represent the

different experimental conditions. Each participant was in one of the following conditions: the fee in text (“Text”),

a fee meter without cutoffs or labels (“Meter”), a fee meter with discrete cutoffs (“Discrete Meter”), or a meter

with labels (“Labeled Meter”). For reference, the figure also provides the actual percent of funds that are less

than a given fee (“Actual Value”).

for a cheaper fund (as finding a cheaper fund is

less likely). To measure these potential patterns,

we asked participants for their interest in seeing

an alternative to the fund they had been randomly

assigned.

Overall, we found that there was a positive

correlation between relative cost estimates and

interest in seeing an alternative fund; in other

words, people who thought their randomly

assigned fund was expensive were more interested

in looking at another option. The meters increased

knowledge of relative costs, however, their impact

on interest in an alternative fund was modest,

suggesting frictions between knowledge of relative

costs and behaviors that reduce fees paid.

OIR conducted additional analyses to delve into

this relationship between relative cost estimates

and interest in seeing another fund. Several factors

may have contributed to the weakness of this

relationship, including a lack of knowledge about

the cumulative effect of fees over time and beliefs

that paying higher fees could lead to higher returns.

We asked two additional survey questions to

explore whether people perceive the importance

of fees. First, we asked participants whether they

agree or disagree with the statement “Mutual fund

fees have little impact on a fund’s performance in

the long run.” Only 26% of participants disagreed

or strongly disagreed (5% strongly disagreed),

suggesting that they would not be motivated to

reduce fees.

We also asked participants to report their beliefs

about the relationship between fees and net returns,

depicted in Figure 14. Overall, 20% believe that

higher fees lead to higher returns, about a third

(36%) reported that there was no relationship,

REPORT ON ACTIVITIES: FISCAL YEAR 2024

FIGURE 14. Perceived Relationship Between Mutual Fund Fees and Net Performance

“Which of the following best describes your view on the relationship

between a mutual fund’s expenses and performance?”

Funds with higher expenses (i.e., fees) tend

to have higher net returns (after expenses)

20%

Funds with lower expenses (i.e., fees) tend to

have higher net returns (after expenses)

12%

There is no relationship between expenses

(i.e., fees) and returns

36%

32%

I don’t know

and only 12% believed that lower expenses would

yield higher net returns. While this may be a noisy

indicator of how investors viewed the funds offered

in the experiment, it suggests some investors may

have been willing to pay higher fees with the hope

of achieving higher returns.

We believe that, together, these two survey

questions suggest one barrier to translating

between knowledge of fees and search behavior:

people do not see fees as very important in

determining investment outcomes. If individuals do

not believe that mutual fund fees affect long-run

performance, or believe that higher fee funds will

yield higher returns, it is unlikely that they will seek

lower-cost funds.

Summary of Findings and Discussion

This testing project demonstrates that, in the

absence of additional information, consumers do

not know the distribution of costs in the mutual

fund market (Lesson 1). They tend to estimate

that a variety of expense ratios are about the

same in terms of relative costs. As these estimates

hover around the 40th percentile regardless of the

underlying fee, investors overestimate the cost of

O F F I C E O F T H E I N V E S T O R A D V O C AT E

10%

15%

20%

25%

30%

35%

40%

relatively inexpensive funds and underestimate the

costs of relatively expensive funds. Providing them

with comparative fee information in the form of a

meter substantially improves their understanding

of relative costs (Lesson 2). In turn, this improved

knowledge increases interest in searching for an

alternative fund. However, the increases in search

were small, raising questions about the barriers that

may exist to translating knowledge of relative costs

into subsequent behavior (Lesson 3).

Overall, this project provides a data-driven

approach to understanding potential investors’

reactions to mutual fund fees and fee information.

Academic research raises longstanding questions

about why fee dispersion continues to exist in the

mutual fund market, especially for mutual funds

like S&P 500 index funds, which are arguably

interchangeable except for fees. At the same time,

the policy community has a longstanding interest

in ensuring that investors do not pay too much for

mutual funds. Our results provide an important

demonstration that price dispersion persists because

of lack of knowledge of fees, and that fee meters

may help investors understand cost information in

their investment decisions.

This research also helps illustrate the value that

OIR can contribute to the SEC and broader

research and policy communities, leveraging

the group’s expertise in crafting and conducting

custom, targeted research projects on important

investor issues. The research represents another

step in OIR’s journey to contribute to more

effective disclosure policy, an important component

of the SEC’s broader investor protection mission.

In past annual reports, we have discussed mutual

fund fee meters, fee jargon, performance displays

and benchmarks, and performed holistic testing

on disclosures for a particularly complex product.

Each project has been designed to provide

targeted insights on the product or display under

consideration. Together, they have promise for

moving the needle on investors’ overall experience

with financial products.

This body of work also shows that much more

can be done. In the future, we hope to continue

to pursue research that reimagines investors’

experiences, concentrating on what have become

recurring themes in our disclosure testing—among

these: that simply disclosing information does not

provide meaning or context, that there may be

limits to baseline financial knowledge or education

that constrain the value of disclosures, and that

behavioral frictions to taking action mean that

investors can be informed without increasing their

well-being. We look forward to continued work

with SEC and academic communities on these

important issues.

financial situation, level of financial sophistication,

investment experience, and financial goals,” and

use an “investment profile,” typically consisting

of a series of multiple choice questions, to do

so.56 According to regulatory interpretation by

the SEC, time horizons are important to include

in the investment profile when recommending

an investment strategy. Similarly, broker-dealers

are legally required to determine whether

securities transactions or investment strategies are

appropriate for investors, based on investor profiles

that include time horizon.57

Given the importance of time horizons in

investment advice and decision-making, the

design and consistency of time horizon questions

should be of interest to practitioners interested

in investors’ well-being. In FY 2024, OIR

conducted research to explore how reported

time horizons vary depending on the “response

options” provided to survey respondents.58

Specifically, we varied whether respondents saw

mostly “short-run” options, which listed many

potential answers focusing on the near term (e.g.,

“Less than a week,” “The next week,” “The next

Financial goals can

happen at different

times in the future.

RESEARCH EXAMINING

TIME HORIZONS

A critical component of investment decisions is

their “time horizon,” defined as “the number

of months, years, or decades [needed] to invest

to achieve [a] financial goal.”55 When giving

advice, registered investment advisers are required

to “make a reasonable inquiry into the client’s

REPORT ON ACTIVITIES: FISCAL YEAR 2024

Lesson 1. Whether Response Options are

Short-Run, Mid-Run, Long-Run, or

Open-Ended Impacts Reported

Time Horizons

Using a nationally-representative sample of people,

we asked the following question to measure time

horizons, “In deciding how much of their income

to spend or save, people are likely to think about

different financial planning periods. In planning

your saving and spending, [which of the following

time periods/what time period] is most important

to you?” This question is used on many nationally

representative surveys to measure financial time

horizons and has been analyzed to understand use

of investment products, even though the question

is not restricted to investment decisions .59

We find that people’s reported time horizons are

shortest when they see short-run options, longest

when they see long-run options, with mid-run and

open-ended responses falling in between. When

people see the set of short-run response options,

they give time horizons greater than one year 18%

of the time. When people see long-run response

options, they report time horizons greater than

one year 74% of the time (see Figure 15). Given

that broker recommendations and investment

advice from advisors are partially determined by

time horizon questions, this research implies that

O F F I C E O F T H E I N V E S T O R A D V O C AT E

FIGURE 15. Proportion of Respondents

Reporting a Time Horizon of Greater than

One Year, by Condition

Closed Options

Time Horizon Greater Than 1 Year

month”), or mostly “long-run” options, which

listed many potential answers focusing on more

distant periods (e.g., “The next 10–15 years,”

“The next 15–20 years,” “More than 20 years”).

Additionally, two other groups of respondents

saw mostly “mid-run” options, with intermediate

time periods, or an “open-ended” format, which

allowed them to write any time period in a

fill-in-the-blank format. Importantly, however, in

all conditions, we designed the response options

so that each set had a clear cutoff at one year,

allowing us to classify all responses into longer or

shorter than one year.

Open

Option

74.0%

75%

50%

37.6%

31.1%

25%

18.0%

Short-run

Mid-run

Long-run

Openended

Condition

This figure shows the proportion of respondents

providing a time horizon of greater than one year,

depending on the response options provided to the

time horizon question.

the choice of response options may dramatically

change investment allocations coming from

brokers and advisors.

Lesson 2. Mid-Run Responses are Closest

to Open-Ended Responses, Likely Making

Them the Most Accurate

Past research generally finds that open-ended

questions allow people to answer questions in

the most natural way,60 thus resulting in the most

accurate estimates. Therefore, we included an

open-ended condition which allowed participants

to express time horizons in the way that was

most natural to them. When we compare time

horizons from this open-ended condition to time

horizons provided in the short-, mid-, and long-run

conditions, we find that those from the mid-run

condition are closest to the open-ended time

horizons (see Figure 15). This alignment suggests

that, of the sets of response options we tested,

the mid-run options result in the most accurate

estimates of people’s time horizons.

An alternative to the mid-run response options

would be to administer the open-ended version of

the question. As found in past research, however,

people are more likely to skip open-ended

questions, which may signal that this question

is more burdensome to answer. Specifically,

skip rates are roughly 3.4% for the open-ended

question, versus at most 0.1% among the closeended questions, which limits the total coverage in

our data.

Discussion and Conclusion

To our knowledge, past research has not explored

the time horizons used in investor profiles. On

publicly posted investor profiles, we see that short

time horizon options include “Immediately” to

“0–5 years”, while long response options vary

from “10+ years” to “more than 20 years.” The

responses we examined in our research varied

less dramatically than these profiles, yet we find a

56-percentage point difference in the proportion

of respondents providing time horizons greater

than one year. We therefore suspect that people’s

responses may be substantially impacted by the

investor profile question they encounter. Having

a substantially different time horizon should

dramatically change an investor’s optimal asset

allocation, according to economic models of

optimal investing behavior.61 Such different asset

allocations could substantially impact portfolio

returns and risk. Yet, we do not see a strong

financial justification for why variation in time

horizon response options should impact the asset

allocation recommendation investors receive.

We examined the effects of response options on

time horizons using a commonly-administered

question that pertains to a range of financial

decisions, including saving and spending. While

the results of this research should be replicated in

an investment context, these results suggest that

brokers and advisors could consider using the

set of mid-run response options, as they result

in reported time horizons that are most similar

to open-ended responses. When there is some

personal interaction between clients and brokers

or advisors, asset allocation differences coming

purely from question differences may be reduced

through additional discussion of financial goals

and their timelines.

REPORT ON ACTIVITIES: FISCAL YEAR 2024

“

It is all too clear that we have entered a new

era, where protecting individuals from financial

predators will require superior tactics and

greater resources.”

MESSAGE FROM

THE OMBUDS

his Report on Activities warns of a

looming complex investment fraud

crisis that could threaten the stability

of our markets, our banking systems,

and our lives. Professional fraudsters prey on

victims in a digital world with no borders, through

anonymous crypto transactions, and with endless

opportunity to exploit our dependence on social

media and technology. Anyone can fall victim to

complex investment fraud—irrespective of party,

demographics, location, or socioeconomic status.

The exceptional scope and staggering financial

impact of the current fraud crisis has been the

subject of many alarming law enforcement reports

and alerts. It is all too clear that we have entered

a new era, where protecting individuals from

financial predators will require superior tactics and

greater resources. We urge Congress to provide

the SEC, other financial regulators, and law

enforcement agencies with the funds necessary to

combat this criminal activity. Anything less than

a fully resourced, coordinated strategy across law

enforcement and regulatory leadership may fail to

quell this rising tide of fraud.

We also urge Congress to help restore investor trust

in the agencies established to protect them. In the

Ombuds Office, we hear the frustrated voices of

investor distrust every day. There is a fundamental

disconnect between investor perception of the SEC

and what the SEC does, every day, on their behalf.

This disconnect could prevent us from reaching the

investors who most need our help.

It has been my honor to serve as the SEC Ombuds

for over two years. In this role, I am proud to have

led a team that assisted thousands of investors,

conducted extensive research and reported

groundbreaking findings on mandatory arbitration,

and to have seized every opportunity to introduce

the voices of retail investors throughout the

Commission. Now, as I step down from my role

this December, I would like to take the opportunity

to introduce the staff

of the SEC to members

of Congress and to the

investors that we serve.

For almost ten years, I

have called the SEC my

professional home. The

colleagues and friends I

have met are among the

most knowledgeable,

goal-oriented, conscientious professionals I’ve

encountered in my 20-year legal career. The work

of the agency is intensely complex and continually

evolving, as our markets evolve to increasing levels

of complexity. But agency staff are zealous in the

execution of its innumerable tasks, guided at every

step by the highest levels of ethical standards.

SEC staff tirelessly educate themselves on new

and developing areas of law and emerging market

events, products, and trends. They are, at all times,

cognizant of and dedicated to fulfilling the agency’s

mission: to protect investors; maintain fair, orderly,

and efficiency markets; and to facilitate capital

REPORT ON ACTIVITIES: FISCAL YEAR 2024

formation. Fulling these obligations sometimes

requires working late nights, weekends, and long

hours—with no expectation of remuneration,

recognition, or reward—because the work must be

done to serve the public interest.

I would like to thank my SEC colleagues for their

collaboration, their shared knowledge, and their

assistance in fortifying the work of the Ombuds

Office for the past two years. And I would like to

express my profound appreciation to the Ombuds

team, without whom the work of this Office

would not have been possible. Your dedication

is unparalleled, your integrity and courage

unmatched. With your support, this tiny office

has achieved outsized results for the protection of

investors everywhere.

As I write this, I recognize I am leaving the best

and most impactful role I might ever have. So, I

save my final thank you to the Investor Advocate,

Cristina Martin Firvida, for entrusting me to serve

in this capacity. I will take the knowledge and the

empathy gained from this experience and carry it

forward throughout my career.

With gratitude to the agency that has forged me

into a better lawyer and a better person, and with

the hope that Congress will support the SEC in

quashing the rising tide of fraud—I humbly submit

this Ombuds Report on Activities for the Fiscal

Year 2024.

Respectfully Submitted,

STACY A. PUENTE

Ombuds

O F F I C E O F T H E I N V E S T O R A D V O C AT E

WHO WE ARE

The Securities Exchange Act requires the Investor

Advocate to appoint an Ombudsman (Ombuds)

to act as a liaison for retail investors to relay their

concerns and questions about the Commission

and the self-regulatory organizations (SROs) the

Commission oversees.62 The Ombuds staff consists

of an experienced team of lawyers, law clerks,

and paralegals, each with differing subject matter

expertise, all dedicated to providing personalized,

tailored assistance to the retail investors that

contact the Ombuds Office for help. Through

direct engagement with investors, relevant parties

within the Commission, and external stakeholders

committed to investor protection issues, the

Ombuds Office fulfills its statutory duty to help

retail investors resolve issues relating to the

Commission and SROs.

Among other statutory duties, the Ombuds must

submit biannual reports to Congress describing the

work of the office and its effectiveness in assisting

retail investors.63 This Ombuds’ Report provides a

look back on the Ombuds’ activities for the period

October 1, 2023 through September 30, 2024, and

discusses the Ombuds’ objectives and outlook for

Fiscal Year 2025.

WHAT WE DO

As noted above, the Ombuds is required by

statute to:

1. help retail investors resolve questions

and complaints they may have with the

Commission or with SROs the Commission

oversees;

2. review and make recommendations regarding

policies and procedures that encourage

investors to present questions to the Investor

Advocate regarding compliance with the

securities laws;

3. take steps to ensure the confidentiality of

investor communications with our Office; and

4. submit biannual reports to the Investor

Advocate that describe the activities and

evaluate the effectiveness of the Office.64

HOW WE HELP

Our primary responsibility is to assist retail

investors by resolving concerns, questions, and

complaints about the SEC and the SROs subject

to SEC oversight. We accomplish this in several

ways—most commonly by providing information,

making referrals, and collaborating with other

divisions, offices, and SROs about complaints that

impact investor interests.

Figure 16 illustrates the process by which we

receive and assist investors with their requests:

Additionally, we submit credible allegations

of securities violations to the Divisions of

Examinations and Enforcement for potential

examination, investigation, or action. We study

and report on issues of significant investor

impact, assessing the effects of policies or

practices on retail investors. Last, we inform the

Investor Advocate and other interested parties

within the Commission about trending investor

protection concerns.

REPORT ON ACTIVITIES: FISCAL YEAR 2024

FIGURE 16. The Process by Which We Receive and Assist Investors with Their Requests

Review

The Ombuds team reviews all incoming investor

correspondence to determine if and how we may assist.

Research

The Ombuds team identifies the nature of the issue, conducts

tailored research, and engages with appropriate personnel

within the Commission or SROs to gather relevant information.

Resolve

The Ombuds team works to resolve investor

questions and complaints by providing

investors with requested information and

access to additional resources, by escalating

certain matters through appropriate channels, when

necessary, and by monitoring outcomes.

HOW TO CONTACT US

Our primary means of communication with

the public is through the Ombudsman Matter

Management System (OMMS), an online portal

for receiving, responding to, and managing data

submitted to our Office. The public can also

INVESTOR VOICES, BY THE NUMBERS

The Ombuds team maintains

records in OMMS of all submissions

and responses handled by our

Office. Matters are assigned a label

or “Primary Issue Category,” reflecting the nature

of the issues raised in the submission.65

In tracking investor submissions by volume and by

Primary Issue Category, OMMS may serve as an

early warning system, flagging existing or potential

risks for retail investors.

O F F I C E O F T H E I N V E S T O R A D V O C AT E

During the Reporting Period (October 1, 2023 –

September 30, 2024), the Ombuds Office received

and processed 2,772 matters submitted by U.S.

and foreign investors, market participants, and

other interested members of the public. Figure 17

illustrates the number of matters divided into 12

Primary Issue Categories, which are used to classify

the nature of the submission.

In addition, the Ombuds team made approximately

3,390 follow-up emails, phone calls, and other

forms of correspondence to resolve the 2,772

matters received—for a combined total of 6,162

contacts with or on behalf of submitters from

October 1, 2023, to September 30, 2024. Figure 18

details the number of follow-up contacts with the

public, separated by Primary Issue Category.

The volume of matters submitted to the Ombuds

Office and the team’s efforts to resolve these matters

continue to grow over time. The total number of

matters received in FY24 (2,772) increased by six

percent from FY23 (2,605). More notably, the total

number of contacts in FY24 (3,390) marked a 20

percent increase from the number of contacts in

FY23 (2,829). The growth in both metrics suggests

two potential conclusions: (1) the public is more

aware of the SEC Ombuds function, and more

frequently contacts the Ombuds Office to resolve

their questions, complaints and concerns; and (2) the

matters received by the Ombuds team are increasing

in complexity as well as number, requiring the

Ombuds team to resolve these matters through a

greater number of contacts on the public’s behalf.

FIGURE 17. Matters by Primary Issue Category,

October 1, 2023 – September 30, 2024

We note, for example, that Fiscal Year 2024 saw the

creation of a new primary issue category for “SEC/

Other Impersonators.” This category was created in

response to an influx of matters where the SEC’s or

other regulator’s seal, and/or the name or signature

of a real or purported SEC or other regulator

employee were fabricated as part of a fraudulent

scheme. Given the sensitivity surrounding these

matters, they involve specific processing and

FIGURE 18. Contacts by Primary Issue

Category, October 1, 2023 – September 30,

2024

0.32%

0.03%

0.35%

0.25%

12%

18%

12%

20%

13%

34%

13%

30%

Allegations of securities law violations (408)66

Allegations of securities law violations (247)

Atypical matters (61)

Atypical matters (543)

Inquiries about corporate disclosure/

registration (85)

Inquiries about corporate disclosure/

registration (57)

FINRA Complaints/Questions/Procedures (130)

FINRA Complaints/Questions/Procedures (74)

Investor Account matters: (840)

Investment products- questions/complaints (82)

Non-SEC/Other matters (351)

Investor Account Matters: (1,136)

Investment Products-Questions/Complaints (110)

Non-SEC/Other Matters (431)

SEC Investigations/Litigation/

Enforcement Actions (175)

SEC Investigations/Litigation/Enforcement

Actions (111)

SEC/Other Impersonators (195)

SEC/Other Impersonators (91)

Other SRO Complaints/Questions/Procedures (30)