Jul. 22, 2020
To whom it may concern, As a normal citizen, I am extremely concerned about the proposed S7-80-20 AUM threshold changes. I fail to see how raising the reporting threshold to such a high number will do anything but hurt small investors like me on top of reducing public companies' opportunity to know more about who their shareholders are. Since when is less transparency and less data ever a good thing? The only people this change will benefit are the players already big enough to actively manipulate the market simply by the sheer volume of their plays, but now with this change they will have the benefit of doing it without warning. For instance, some investors (myself included) may want to avoid stocks over-owned by players who have a history of pseudo market manipulation due to the high level of risk they encourage. This rule change greatly reduces my ability to reduce my own risk and gives even more power to those who have more to gain and less to lose from market volatility from the beginning. Not only that but the "justification" for the rule changes are highly questionable to begin with, but 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. The motivation for this proposal is highly suspect and should result in it being dismissed off hand with prejudiced. Woodrow Martin Sent with ProtonMail Secure Email.