Subject: S7-08-20
From: Davide Accomazzo
Affiliation:

Jul. 14, 2020

 


To whom it may concern:

I am sending the present email to voice my utter discontent with the new proposed change by the SEC to significantly increase the minimum level of AUM required to file 13F quarterly forms. The proposed new rule is a blatant attempt reduce transparency in the markets. The following are additional reasons that highlight how misguided the size of the increase in minimum AUM is:
· 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?
I look forward to a more sensible approach to this issue.
Best regards,
Davide Accomazzo