Sep. 28, 2020
Comments of H. Mannaa on S7-08-20 Subject: File No. S7-08-20 From: Hisham Mannaa, CFA -------------------------- September 28, 2020 The original purpose of the 13(f) disclosure is stated below. I believe the current proposal to increase the threshold of reporting runs against every one of the three key reasons for the creation of the 13(f). It obscures data and reduces the investor confidence in the integrity of the US Markets. The section 13(f) disclosure program had three primary goals. First, to create a central repository of historical and current data about the investment activities of institutional investment managers. Second, to improve the body of factual data available regarding the holdings of institutional investment managers and thus facilitate consideration of the influence and impact of institutional investment managers on the securities markets and the public policy implications of that influence. Third, to increase investor confidence in the integrity of the U.S. securities markets