Jul. 14, 2020
Dear SEC, I'm writing to express my concern over the recent proposed change in legislation, which would alter the 13F filings. This proposal would change the AUM threshold that investment managers must meet every quarter from $100 million to $3.5 billion! To put it in perspective, for the most recent quarter, that would reduce the number of funds that disclosed their holdings to the public from 5,283 to 549 or almost 90% of all filers. $2.3 trillion in investment holdings would no longer be disclosed to the public resulting in loss of transparency and valuable insight. When Congress first adopted Section 13(f) it did so to “stimulate a higher degree of confidence among all investors in the integrity of [the US] securities markets.” Taking this data away will have the opposite effect. Transparency is what gives investors confidence in US markets. This is an absurd proposal, I have over 2 million dollars invested in the US stock market and I rely heavily on 13F's to base my decisions. If this passes, I will remove 80% at least of my equity in the US market and trade other international markets. The reason people invest in US equities is because of transparency and reliability. IF you take that away, you're just like any other market, and people will move to other markets where the returns are much higher. Thank you Hope you can convince legislators of the absurdity of this all. --