Subject: S7-08-20
From: Richard Sinise
Affiliation:

Aug. 03, 2020


I really hope you reconsider this rule. As a small investor who has small size investment advisors manage my inherited IRA, I use the quarterly reporting of stock holdings to insure the manager is treating me fairly (am I getting stock positions that others are) and the the value nature of the manage (fo which I selected the manager is being followed overall by his firm. I look at the stock holding to insure value stocks are his/her predomite focus.

In fact I selected the manager looking at their 13-D holdings as I find many value managers are really buying speculative stocks .

I just do not see the use for this rule. I would guess every manager who manages $1 to $3 billion assumes and plans that they will get larger. The software I suspect is cheap and easy to upload holdings and these managers probably already have it in their Advent package.

Please reconsider.

Sent from Mail for Windows 10