Jul. 14, 2020
Dear SEC staff, I would like to comment on your proposed rule change - altering the size of asset managers required to report equity positions. Given disclosure requirements for mutual funds and ETFs - both very beneficial to the public - I think that changing these rules could have some negative consequences. It could create "innovation" away from offerings with disclosure to offerings without. This kind of second-order, unintended consequence should be very carefully considered. Thank you, Andy Parker