Subject: File No. S7-08-15
From: John Wahh

May 27, 2015

I have a few concerns regarding the SECs data gathering rulemaking:

The SEC is asking registrants to undertake very expensive efforts. This effort will cost 500+ fund complexes millions of dollars apiece to comply. I wonder if it would be more cost effective for the SEC to purchase a subscription to Morningstar or Lipper which should get the agency most of what it needs for a few thousand dollars per year.

The SEC is asking for a lot of structured data.

o Will the agency have the resources to use this data? I note that to my knowledge, the agency does not use XBRL tagged mutual fund information.

o Will the tagging of big data benefit the high frequency tech savvy traders who will have the capabilities to digest vast quantities of data very quickly to the detriment of other investors?

Will this effort foster high frequency trading and provide a particular benefit to the bIg players?

Will the SEC provide tools so that every day investors can uSe this data (perhaps in conjunction with mutual fund XBRL data)?

Must of the information being asked for is already located in other documents or is otherwise available on EDGAR (e.g., if a series has been submitted for a shareholder vote). Why repeat the information?

o If a series had a shareholder vote, there would be a proxy filed associated with the series on EDGAR. The SEC does not need to ask questions about information it can already retrieve on an automated basis.

The SEC should further this tagged data effort to regulatory filings (e.g., rule 17f-2 filings, Fidelity bond data, audit opinions, etc.). Structured data would be very useful for the agency to process this data. If this is done, the SEC can poll data very quickly instead of opening tens of thousands of filings to read the content.

It is still unclear to me why the SEC needs this data. The SEC are not merit regulators. It seems like the SEC intends to use this data to second guess fund management and board determinations.