14 professional presentations - morningstar · pdf file14 professional presentations dividend...

March 2013

Dear Investment Professional: FINRA COMPLIANCE The 2013 Morningstar Principia Presentations and Education materials have been

reviewed by FINRA. Attached are the private ruling letters with FINRA’s

comments for: Product Letter Review Date 14 Professional Presentations Dividend Investing PPT October 10, 2012 Downturns and Recoveries PPT July 16, 2012 Exchange-Traded Funds PPT March 6, 2012 Global Investing PPT November 16, 2012 Growth and Value Investing PPT June 28, 2012 Investing for Retirement PPT June 28, 2012 Investor Behavior PPT July 23, 2012 Portfolio Diversification and Performance PPT November 16, 2012 Principles of Investing PPT April 18, 2011 Retirement Income PPT July 24, 2012 Risk and Volatility PPT July 23, 2012 Stocks and Bonds PPT November 16, 2012 Target-Date Funds PPT July 23, 2012 Taxes and Investment Performance PPT April 18, 2011 3 Sales Ideas Mixed Income PDF one-page handout August 12, 2009 Playing Catch-Up PDF one-page handout August 26, 2008 Small Change PDF one-page handout November 4, 2004

All necessary changes addressed in the letters have since been made. Please note that the materials were submitted to FINRA in complete presentation or brochure format and individual sales idea format. Use in formats other than what was submitted is not covered by these letters. As per FINRA guidelines, materials may be updated with new data without the need to resubmit for their review. For those materials that were submitted before year-end data was available, we have since updated that data.

Please note that some materials were submitted to the NASD before the name change to FINRA. The name change does not affect review status. In each of the FINRA PowerPoint presentation letters, the number of pages specified may not be equal to the actual number of pages in the current presentation. This is due to the recent deletion of slides in select presentations. The letters are still applicable.

October 10, 2012

Denver Ignacio Morningstar Investment Services, Inc.22 W. WashingtonChicago IL 60602

Reference: FR2012-0910-0152/E Org Id :112525

REVIEW LETTER

1. Dividend Investing PPT PresentationRule: 221012 pages Fee: $145

Total Fee: $145 Attention: Denver Ignacio

We have reviewed this material as an Independently Prepared Reprint, as that term is defined in Rule 2210(a)(6), and understand that your firm requests “blanket approval” for the use of this presentation by FINRA member firms.

This material appears consistent with applicable standards. Please be advised that our review pertains only to the 12-page presentation submitted and no other materials. Member firms do not need to file the report with this Department as long as it is not materially altered.

If this report is used as something other than an Independently Prepared Reprint, it may be subject to the filing requirements and will be subject to the other provisions and Guidelines, as applicable, of Rule 2210.

If you should have any questions, concerns, or comments, please contact me at (240) 386-4500.

Reviewed by,

Mario GreszesAssociate Supervisor

mg

FINRA has amended Section 13 of Schedule A to the By-Laws governing the review charge for advertisements, sales literature, and other such material filed with or submitted to FINRA. Effective July 2, 2012, the base review charge (for up to 10 pages) will rise from $100.00 to $125.00. The base review charge for expedited reviews (for up to 10 pages) will rise from $500.00 to $600.00. The per page review charge for expedited reviews will rise from $25.00 per page to $50.00 per page in excess of 10 pages. Submissions received by the Advertising Regulation Department prior to the change will not be affected by the fee increases.

This year’s Advertising Regulation Conference will be held on October 25-26 in Washington, D.C. For more information and to register, please view our online site at: www.finra.org/conferences/adreg3.

NOTE: This review is limited to the communication that was filed. We assume that the communication does not omit material facts, contain statements that are not factual, or offer opinions that do not have a reasonable basis. This communication may be described as “Reviewed by FINRA” or “FINRA Reviewed”; however, there must be no statement or implication that this communication has been approved by FINRA.

Please send any communications related to filing reviews to this Department through the Advertising Regulation Electronic Filing (AREF) system or by facsimile or hard copy mail service. We request that you do not send documents or other communications via email.

http://www.finra.org/conferences/adreg3

July 16, 2012


Reference: FR2012-0531-0165/E Org Id :112525 Link Reference : FR2009-1106-0125

REVIEW LETTER

1. Downturns and RecoveriesRule: 221013 pages Fee: $130


We have reviewed this material as an Independently Prepared Reprint, as that term is defined in Rule 2210(a)(6), and understand that your firm requests “blanket approval” for the use of this report by FINRA member firms.

This material appears consistent with applicable standards. Please be advised that our review pertains only to the 13-page report submitted and no other materials.

Member firms do not need to file the report with this Department as long as it is not materially altered.


Reviewed by,


mg

March 6, 2012



REVIEW LETTER

1. Exchange-Traded Funds PPT presentationRule: 221014 pages Fee: $140


We have reviewed this material as an Independently Prepared Reprint, as that term is defined in Rule 2210(a)(6), and understand that your firm requests “blanket approval” for the use of this reprint by FINRA member firms.

A revision is necessary for the material submitted to be consistent with applicable standards. We have the following specific comments.

With respect to the discussion on page 14 regarding leveraged and inverse ETFs, in order to make the presentation complete and balanced, and to provide the reader with a sound basis to evaluate investment in these products, pursuant to the standards set forth in Rule 2210(d)(1)(A), the presentation must be revised to include clear and prominent disclosure of the substantial risks associated with these products, specifically including but not necessarily limited to, disclosure that they are not appropriate for a long-term or buy and hold investment strategy, that these investments are designed for short-term or intraday trading for investors seeking daily leveraged investment results and who intend to actively monitor and manage their investments as frequently as daily.

Because of the revisions required, we are unable to provide blanket approval at this time.

Reviewed by,


mg



November 16, 2012


Reference: FX2012-1113-0452/E Org Id :112525 Link Reference : FR2011-0328-0074, FR2011-0328-0070

REVIEW LETTER

1. Global InvestingRule: 221019 pages Fee: $1050



This material appears consistent with applicable standards. Please be advised that our review pertains only to the 19-page report submitted and no other materials. Member firms do not need to file the report with this Department as long as it is not materially altered.


Reviewed by,


mg

June 28, 2012

Kyle Gisbrecht Morningstar Investment Services, Inc.22 W. Washington StreetChicago IL 60602

Reference: FR2012-0515-0282/E Org Id :112525 Link Reference : FX2009-0217-0232

REVIEW LETTER

1. Growth and Value InvestingRule: 221012 pages Fee: $120

Total Fee: $120 Attention: Kyle Gisbrecht

The material submitted appears consistent with applicable standards.

Reviewed by,


aec


June 28, 2012

Kyle Gisbrecht MORNINGSTAR INVESTMENT SERVICES, INC.22 W. Washington StreetChicago IL 60602


REVIEW LETTER

1. Investing for RetirementRule: 221015 pages Fee: $150




We direct your attention to the “Benefits of Deferring Taxes” slide on page 11 of the presentation. In order to make the presentation fair, balanced and complete, pursuant to the standards set forth in Rule 2210(d)(1)(A), the explanatory material accompanying the slide must be revised to disclose the fact that changes in tax rates and tax treatment of investment earnings may impact comparative results; and advise readers to consider their personal investment horizon and income tax brackets, both current and anticipated, when making an investment decision as these may further impact the results of the comparison.

We acknowledge that this revision may not have been identified in prior submissions of similar material, and we apologize for any inconvenience occasioned thereby.


Reviewed by,


mg






July 23, 2012



REVIEW LETTER

1. Investor BehaviorRules: 2210, SEC 48212 pages Fee: $120




Given the discussion of total returns and investor returns in mutual funds, and the chart and discussion of the specific performance of an unnamed mutual fund appearing on slide 19 of the presentation, the presentation appears to constitute the first step in the offer of mutual funds for sale. Therefore, in accordance with SEC Rule 482(b)(1)(i), the presentation must be revised to include a statement that advises an investor to consider the investment objectives, risks, and charges and expenses of the investment company carefully before investing; explains that the prospectus contains this and other information about the investment company; identifies a source from which an investor may obtain a prospectus; and states that the prospectus should be read carefully before investing. We note that such a prospectus offer was included on the corresponding slide appearing in the referenced linked submission, FINRA Reference Number FR2009-1106-0123.

Because of the revision required, we are unable to provide blanket approval at this time.

Reviewed by,


mg






November 16, 2012


Reference: FX2012-1113-0466/E Org Id :112525 Link Reference : FR2012-0531-0168, FR2011-0328-0077

REVIEW LETTER

1. Portfolio Diversification and PerformanceRule: 221015 pages Fee: $850





Reviewed by,


mg

April 18, 2011



REVIEW LETTER

1. Principles of Investing PPT presentationRule: 221012 pages Fee: $120



A revision is necessary for this material to be consistent with applicable standards. We have the following specific comments.

We note that the title of the fifth page of the presentation, as well as the content which follows, refers to “Controlling Risk”. However, because this phrasing mitigates the risks associated with investments and is potentially misleading, in contravention of the standards set forth in Rule2210(d)(1)(B), the reference to risk “control” should be toned down (e.g., replace “control” with “manage”). We understand that this comment may not have been made in our review of similar material, and apologize for any inconvenience occasioned thereby.

Please be advised that our review pertains only to the 12-page report submitted and no other materials.




Reviewed by,

Mario GreszesSupervising Analyst

mg NOTE: This review is limited to the communication that was filed. We assume that the communication does not omit material facts, contain statements that are not factual, or offer opinions that do not have a reasonable basis. This communication may be described as “Reviewed by FINRA” or “FINRA Reviewed”; however, there must be no statement or implication that this communication has been approved by FINRA.


July 24, 2012



REVIEW LETTER

1. Retirement IncomeRules: 2210, IM2210-619 pages Fee: $190




We note that, although the presentation contains certain disclosures relating to the Monte Carlo analysis and simulations, because not all of the information required by IM-2210-6, “Requirements for the Use of Investment Analysis Tools”, is provided, the existing paragraph stating that the projections shown are hypothetical in nature must be revised to state the name of investment analysis tool, as prescribed by IM-2210-6(c)(4).

We acknowledge that this revision may not have been identified in prior submissions of similar material, and we apologize for any inconvenience occasioned thereby.


Reviewed by,


mg






July 23, 2012



REVIEW LETTER

1. Risk and VolatilityRule: 221015 pages Fee: $150



This material appears consistent with applicable standards. Please be advised that our review pertains only to the 15-page presentation submitted and no other materials.

Member firms do not need to file the presentation with this Department as long as it is not materially altered.

If this presentation is used as something other than an Independently Prepared Reprint, it may be subject to the filing requirements and will be subject to the other provisions and Guidelines, as applicable, of Rule 2210.

Reviewed by,


mg

November 16, 2012


Reference: FX2012-1113-0481/E Org Id :112525 Link Reference : FR2012-0531-0173

REVIEW LETTER

1. Stocks and BondsRule: 221016 pages Fee: $900





Reviewed by,


mg

July 23, 2012



REVIEW LETTER

1. Target-Date FundsRules: 2210, SEC 48211 pages Fee: $110




Given the discussion of potential benefits of investing in target date funds, the presentation appears to constitute the first step in the offer of these mutual funds for sale. Therefore, in accordance with SEC Rule 482(b)(1)(i), the presentation must be revised to include a statement that advises an investor to consider the investment objectives, risks, and charges and expenses of the investment company carefully before investing; explains that the prospectus contains this and other information about the investment company; identifies a source from which an investor may obtain a prospectus; and states that the prospectus should be read carefully before investing.

Because of the revision required, we are unable to provide blanket approval at this time.

Reviewed by,


mg






April 18, 2011



REVIEW LETTER

1. Taxes and Investment Performance PPT presentationRule: 22108 pages Fee: $100



This material appears consistent with applicable standards. Please be advised that our review pertains only to the 8-page report submitted and no other materials.




Reviewed by,

Mario GreszesSupervising Analyst

mg NOTE: This review is limited to the communication that was filed. We assume that the communication does not omit material facts, contain statements that are not factual, or offer opinions that do not have a reasonable basis. This communication may be described as “Reviewed by FINRA” or “FINRA Reviewed”; however, there must be no statement or implication that this communication has been approved by FINRA.


August 12, 2009

Lisa Derner Morningstar Investment Services, Inc.22 West Washington, 8th FloorChicago IL 60602


REVIEW LETTER

1. Mixed IncomeRule: 22101 page Fee: $100

Total Fee: $100Attention: Lisa Derner


This material appears consistent with applicable standards. Please be advised that our review pertains only to the one-page handout submitted and no other materials.

Member firms do not need to file the handout with this Department as long as it is not materially altered. If this handout is used as something other than an Independently Prepared Reprint, it may be subject to the filing requirements and will be subject to the other provisions and Guidelines, as applicable, of Rule 2210.


Sincerely,

Geojoe ThomasSupervising Analyst

jws This year’s Advertising Regulation Conference will be held on October 21-22 in Washington, D.C. For more information and to register, please view our online brochure at http://www.finra.org/Industry/Education/ConferencesEvents/AdvertisingRegulationConference/index.htm

NOTE: This review is limited to the communication that was filed. We assume that the communication does not omit material facts, contain statements that are not factual, or offer opinions that do not have a reasonable basis. This communication may be described as“Reviewed by FINRA” or “FINRA Reviewed”; however, there must be no statement or implication that this communication has been approved by FINRA.

August 26, 2008

Lisa Derner MORNINGSTAR INVESTMENT SERVICES, INC.225 W Wacker Dr, 8th FloorChicago IL 60606

Reference: FX2008-0821-0299/E Org Id :00112525

REVIEW LETTER

1. Playing Catch-UpRule: 22101 page Fee: $500

Total Fee: $500

Attention: Lisa Derner


This material appears consistent with applicable standards. Please be advised that our review pertains only to the one-page handout submitted and no other materials.

Member firms do not need to file the handout with this Department as long as it is not materially altered. If this handout is used as something other than an Independently Prepared Reprint, it may be subject to the filing requirements and will be subject to the other provisions and Guidelines, as applicable, of Rule 2210.

Please feel free to contact me if you have any questions regarding this matter.

Sincerely,

Ruth M. FinglassSupervising Analyst

elw

This year’s Advertising Regulation Conference will be held on October 2-3 in Washington, D.C. For more information and to register, please view our online brochure at: www.finra.org/conferences/advertisingregulation

NOTE: As a FINRA member, you are responsible for determining whether any communication with the public, including material filed with the Department, complies with all applicable requirements. The views expressed herein are solely advisory and do not constitute findings of compliance with, or violations of FINRA or SEC rules. It is assumed that the material does not omit material facts, contain statements that are not factual, or offer opinions that do not have a reasonable basis.

14 professional presentations - morningstar · pdf file14 professional presentations dividend...

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