Subject: file number S7-08-20
From: Glenn Lawyer
Affiliation:

Aug. 08, 2020

Dear SEC,

I am a private person. My primary retirement savings consists of my IRA
account.

I rely on 13F filings to manage my investments.

I have learned that you are considering raising the AUM threshold for
reporting from its current level of 100 million to 3.5 billion.
https://www.sec.gov/rules/proposed/2020/34-89290.pdf

I understand that this would mean that approximately 90% of current 13F
filers would no longer have to file.

This would massively reduce the market transparency I rely on to enable
me to fund my pension.

Commissioner Allison Herren Lee understands the needs and mission of the
SEC much better than I do. I refer you to her comments on the matter,
https://www.sec.gov/news/public-statement/lee-13f-reporting-2020-07-10

noting that she clearly does not support the proposed change, citing
numerous points where the proposal goes against established SEC
regulations, norms, principles, and your core mission.

Kind regards,

+glenn

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Glenn Lawyer