Subject: File No. S7-2026-24
From: Gabriella Baggins

I think the SEC needs to reign in ETFs that tout high distribution rates or high income rates. First, this is akin to suggesting a future yield or performance in violation of rule 156 and the antifraud provisions of the federal securities laws. Second, investors confuse income and distributions for performance. Narrative explanations will it resolve that confusion. Many ETFs are also promotion historic distribution rates over other performance measures in violations of rules 482 and 34b-1. Finally, there is no rational reason investors need a fund that pays distributions. If investors need money, they can sell shares. In fact, many investors automatically reinvest dividends. This is not the same as a fund for an old lady to live off dividends from her utility fund. Do a better job of protecting investors. Rule 156, 482 and the antifraud provisions are an effective tool. Now use them!