Subject: 13f reporting changes
From: Brett Robison
Affiliation:

Sep. 09, 2020

I believe it makes sense to raise the threshold for 13f reporting. 


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 and make the data that is collected more relevant to the original intent to monitor larger institutional managers' influence on the market. this proposal seems like a win-win since it will free up more time for us to focus on our clients and their investments and less time that government spends collecting data that doesn’t pertain to the original intent 


One of the other changes proposed is to review the reporting threshold every five years and recommend adjustments accordingly which I do support. 


Thank you 


Brett Robison 


sanctuarywealthmanagement.com 

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