Jul. 14, 2020
Dear SEC, I was the Managing Partner of Pivot Point Capital, a long-only hedge fund from 2005 through 2019. I think the proposed increase in AUM in equities to $3.5B would be a mistake and a bad policy. The administrative burden of filing the13F forms are negligible. We used an outside vendor to upload our forms at a very modest cost and with minimal time on our part. On the other side, the transparency it provided to our investors and others was valuable in my opinion. Should there be any change in policy, I would recommend that it be no more than to increase the AUM limit to $200 or $250M from the current $100M. I found the $3.5B figure truly astounding. Best, Anthony P. Brenner