Jul. 14, 2020
The proposed Rule is deeply concerning for the following reasons: It is being made at the 11th hour by a) an outgoing, "lame duck" SEC Chair, b) who admitted to petitioning the President of the United States for a top law enforcement position in NYC, AG of Southern District of New York (the heart of the investment industry), without the support of even a minority of remaining SEC Commissioners. In fact, in a rare move, some SEC Commissioners immediately and publicly disagreed with Chair Clayton. Raising the reporting threshold to such a high Asset number will severely limit future academic research on markets, investing and securities. It will reduce public companies' opportunity to know more about who their shareholders are, thus making Management teams less accountable. Many managers share 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 proposed rule change makes no sense in current form. The “justification” for the rule change is dubious at best. The costs cited are not reflective of reality. There is no "burden" on small managers. The advancements of technology more than offset any theoretical reporting "burden". JL