Aug. 18, 2020
To whom it may concern: The following are reasons I believe it would be prudent to raise the threshold from the $100 million to the $3.5 billion. The original threshold was adopted in 1975 to obtain data on bigger institutional investment managers' impact on the US equity market. Since then the market has gone from $1.1 trillion to $35.6 trillion. Yet the threshold being observed has not changed with the market. It makes sense that raising the threshold to closely match the market changes over the past 45 years will take away the burden of reporting from smaller managers such as ourselves and make the data that is collected more relevant to the original intent to monitor the larger institutional managers' influence on the market. I also believe it would be prudent to review the reporting threshold every five years and recommend adjustments accordingly. Regards, G Clay Esplin 275 South Fifth Avenue, Suite 151, Pocatello, ID 83201 SanctuaryWealth.net Investment advisory services offered through Sanctuary Wealth Management, LLC.