Subject: S7-08-20
From: William Reese
Affiliation:

Jul. 16, 2020

 


The “justification” for the rule change is highly questionable. When there is less transparency and less data there is greater risk for financial instability Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk. In the event of a significant correction the number of reporting managers would be diminished even further. The S&P suffered a 56.4% decline during the 2007-2009 financial crisis. A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.