Subject: Administrative Proceeding File Number 3-18527
From: Darren Hassey
Affiliation:

Apr. 15, 2020

Dear Sir, 


With reference to the above; Devere fair Fund Distribution, I note distribution is at 7% of invested / transferred value for eligible investors. Where this 7% relates to the lost amount, I suggest the distribution should also include lost investment value of said funds. For example if the S&P 500 (or other reasoned growth measure) increased 30% between the mid point of the eligibility date range until present day, (or such fixed recent date) then distribution should be 7% of transferred value plus 30%, or in this example 9.1% of transferred value. 


Given the distribution terms can only pay up to the net fair fund value before a pro rate amount is distributed this can only ensure maximum benefit to impacted investors. 


Thanks you for your consideration. 


Darren Hassey.