Subject: File No. S7-07-18
From: Charles S Dudney, Ph.D.
Affiliation: Retired scientist

July 18, 2018

Seven of us are volunteers in the VITA program of the IRS. Each year, we prepare and file about 500 tax returns. 70% of the taxpayers we see are over 60 years of age. Consequently, we see a lot of brokerage statements, many of which are handed to us by an elderly person stating that they have no idea what these numbers mean and that they need help. A cursory review of many brokerage statements reveals high fees ( $1,000) and small capital gains ( $2,000). In other words, these accounts are being churned.

Please implement rules to prevent (or at least reduce) the fleecing of our elderly.