Jul. 15, 2020
To Whom It May Concern: My investment community managers have informed me of a rule change regarding Reporting Threshold for Institutional Investment Managers - File No: S7-08-20 is being considered. As you know, currently institutional traders with account values over $100M must report their holdings on a quarterly basis. These filings are submitted on from 13F. The SEC is proposing raising the 13F threshold to $3.5B. This rule change will remove accountability and transparency from management of "small" assets. I do not believe that under 3.5B is "small" and it is not an administrative burden on "smaller managers". The 13F filed by these managers is one important piece of information when we investors do our due diligence. I urge you to reconsider. Thank you, Steven C Winslow Dallas, TX It is our opinion that this is not so much about administration burden or costs. It is more about accountability and transparency. We believe there should be more transparency - not less.