Subject: s7-02-23: WebForm Comments from Anonymous SEC Staffer
From: Anonymous SEC Staffer
Affiliation:

Mar. 8, 2023



March 8, 2023

 The rule needs to be clearer as to what a diversified fund is.  Is concentration 25% (as it is used in the Investment Company Act?  Is it 80% as is the threshold for the fund Names Rule? Is concentration based on sector (energy), industry (natural gas)
or subsector (Natural gas pipelines)?
As additional examples:
+A global fund says it may investment more than 25% in a single country. Is it concentrated?
+An SP 500 is currently has more than 25% allocated to technology, is it concentrated?

I recommend just having the staff report all funds.  If you are automating the reporting process, then there is no burden to require reporting of diversified funds.

I am concerned about providing third-party to access our financial information.  I assume this third-party will use robust cybersecurity protocols.  However, the SEC and federal government has had cybersecurity incidents in the past with respect to employee data.