Sep. 08, 2020
To Whom it May Concern: I am writing in favor of the proposed rule to update the reporting threshold, effectively raising the amount needed to file. 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. Smaller firms, and those who would prefer to manage a smaller number of clients, can focus on fiduciary duties on existing clients while their clients' portfolios have grown with the market in essentially a "passive" manner due to how rapid the growth of the equity market has been. Additional regulatory reporting weighs heavily on smaller firms, and especially for the actual market share they represent, this threshold is outdated. I am in favor of revisting the intent of the original threashold, as it was to regulate those with a larger overall market share - Larger firms, and those intending to become large firms with the personnell capable of handling an additional regulatory burden, without harm to the client experience. Sincerely,