Jul. 14, 2020
Dear SEC, Given the SEC's emphasis on a level fair playing field, this rule change makes no sense. The reasoning behind the proposed change is the “possible” reduction in costs and burdens to smaller managers. This justification is nonsense. It is a highly automated process that effectively costs nothing. The claimed cost savings are completely inaccurate. This will hurt small investors such as myself and limit transparency in the financial system. · Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities. · Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are. · Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense. · The “justification” for the rule change is highly questionable. · When is less transparency and less data ever a good thing for the small investor? · Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk. In the event of a significant correction the number of reporting managers would be diminished even further. The S&P suffered a 56.4% decline during the 2007-2009 financial crisis. A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.