Jul. 14, 2020
Comments and Feedback Regarding S7-08-20 As a financial advisor I am deeply concerned by the proposed 13F reporting and transparency changes laid out here: https://www.sec.gov/rules/proposed/2020/34-89290.pdf?__s=zgsannv5s3p3yemmbydv My biggest concern is regarding the change from $100M to $3.5B and the minimum for required reporting. 13F statements provide much needed transparency for investors. 13F Disclosures provide multiple benefits to small investors: Important Disclosure and transparency for investors Allows for unbiased oversight and analysis of fund holdings Ability for further historical and academic research to better understand investment methods to improve investor outcomes From my perspective as a Financial Advisor, using 13F reports provides me the ability to oversee and research manager performance without relying on their provided marketing materials. Through 13F statements we are able to observe, analyze, and most importantly verify that what they tell the public matches up with their actions through their 13F disclosure documents. History has shown us fund managers have the tendency to “talk amongst themselves” where they share ideas and information. Small mom and pop investors do not have access to this level of information for their investing. The use of 13F statements is a great way for retail investors to observe the moves of large institutional traders and provides transparency if something goes wrong. Throughout history when has less transparency ever been good for American investors? I strongly discourage the idea of increasing the reporting threshold for 13F statements. The SEC has worked hard to bring to light hidden fees and outrageous commissions for the benefit of investors. Changing these transparency rules would be a big step in the wrong direction. I appreciate your consideration of this topic. I urge you not to change the reporting threshold from $100M to $3.5B. Too many managers would be excluded. From my perspective, and increase to $200M or $250M would be appropriate if any increase is required. Best Regards, Kern T. Kern Campbell, MBA Financial Analysts A Member of Advisory Services Network, LLC 2626 Glenwood Avenue, Ste. 510 Raleigh, NC 27608 (919) 787-7325 (800) 722-5862 (919) 782-1941 fax kern@fainvestors.com Connect via LinkedIn | Free Retirement Checkup | FA Market Insights Blog Securities offered through Triad Advisors, a Registered Broker/Dealer, Member FINRA/SIPC. Investment Advisory Services offered through Financial Analysts, a member of Advisory Services Network, LLC. Managed Futures offered through FFI Alternatives, LLC, member of the National Futures Association (NFA) and registered with the Commodity Futures Trading Commission (CFTC). Triad Advisors, Advisory Services Network, LLC, and FFI Alternatives, LLC are not affiliated.