Jul. 14, 2020
Hello, I am writing to provide comments on S7-08-20. As an individual public investor for the last 10 years, I have found 13-F data to be valuable in providing transparency and leveling the playing field for investors like myself and many others in the US. 13-F filings have become a staple in the investor community, where the 45 day window post the quarter end is bookmarked on all of our calendars to learn about what other securities investors are looking at and increase collaboration. In the private markets, such as venture capital, idea sharing and opportunities are limited to an elite circle, public investing is great because ideas are democratized (albeit with a 45-day delay) and available to any individual investor. 13-Fs are unique to the US markets, and I believe it's a staple why US equities have strong levels of trust and transparency compared to other markets in the world. On the flip side, it's important for companies to understand who is their shareholder and how that can play into their investor relations strategy. Again, going through 13-Fs is a staple for many investor relations jobs and by limiting disclosure will affect the way much of this analysis is conducted today. I am requesting that the proposed rule change be considered for full withdrawal. I am happy to discuss my thoughts or perspectives with your office in case it may be helpful and greatly appreciate the consideration. Best Regards, Rick Brubaker