Subject: S7-08-20 Reporting Threshold for Institutional Investment Managers
From: Arden Davis
Affiliation:

Jul. 31, 2020

Proposed changes in this rule benefits the billion dollar investors at the expense of small investors like myself.
The current 13F filings is a research tool small investors as myself frequently refer to in making investment decisions.
By changing the form $100 million threshold to $3.5 billion threshold will eliminate 90% of the 13F filings thus taking away a significant source stock investment research data.

I understand why a change like this has been proposed by money managers but it is at the expense of the small individual investors.

This proposed Rule change to Threshold reporting increase to $3.5 billion should not go forward. Keep the reporting threshold as is now for a more level playing field providing better opportunity for the small investors..

Arden Davis