Subject: File No. S7-07-18
From: William Michael Cunningham, AM, MBA
Affiliation: Creative Investment Research

June 5, 2019

See: Testimony at US Department of Labor's Fiduciary duty hearing held on August 13, 2015 at the Department of Labor HQ in Washington, DC. https://youtu.be/kOGS-DdLYe0

We incorporate these comments by reference.