Jul. 13, 2020
This is very simple - Regarding: 13-F. Forms and regulations should be updated regularly for both efficiency, effectiveness and greater transparency. I'll comment on only one aspect of the proposed rule change - the required filing threshold. Raising the current threshold from $100 million in assets to $3.5 billion simply means the SEC, the one regulatory oversight commission has decided to allow 90% of institutional investors to hide their assets. I'm not sure who talked who into this, but all parties involved seem to be motivated by greed and power and a "hidden agenda" which we all know is not hidden at all. Transparency of information is regarded as a strength, greed is regarded as a weak link. No one enjoys the process of competing forms, well perhaps accountants. So I propose simplifying the forms by 90%. Maintain the threshold of $100 million in assets as institutional investors' behavior is what is regulated, not money. The SEC was established due to institutional investors' inappropriate and illegal behavior, remember? Just simplify the forms by 90% by requiring both assets and short positions listed that are held on a specified date, require these forms to be filed within 10 days (as they will be simplified by 90%) and do not allow for requests by institutional investors for "confidential treatment". Those are not only my thoughts, but I speak on behalf of those who are not institutional investors and even some clients of institutional investors. Thank you for your consideration and time. Carolyn Cole