February 5, 2022
Thank you for allowing us the opportunity to participate.
It seems the main argument against the proposed rules is that new reporting will be burdensome to fund advisors. However, our modern world no longer requires a staff to generate, print and mail reports. In fact, it is completely unreasonable to suggest the data is not already being produced and reported digitally to senior executives at the firms. It is the very basis of their business planning.
Indeed, any good data analyst could modify their existing reports to produce an SEC report within a days work and reports could thereafter be generated with a keystroke at any time.
Their resistance to report confirms the lack of transparency is being abused, at the expense of retail investors whether they are speculative accounts, or retirement accounts.
We all know the stock market cycles as a normal process and its clear we are at the top of one financial cycle now. What the American public will next face is a large financial draw-down and an election cycle.
Social media and meme stock investigators have deeply changed how the coming cycle will be viewed compared to the 2009 debacle. These investigators are active, well researched, loud, and because they are avowedly apolitical, their momentum is only gaining strength while other issues are causing political divides.
In the next couple years when retirement accounts evaporate and foreclosures return, I expect there will be massive calls on both sides of the aisle for reform and punishment. Transparency reporting efforts will seem like nothing compared to the reporting efforts to respond to the congressional hearings that will be demanded by everyone who is suffering financially. Even the SEC will be preparing for and attending those hearings.
The new rule is a great first-step, thank you. There are many that need to follow, especially if and when the Department of Justice and Congress decide its time they get involved. Repairing the flawed system cannot happen soon enough.