Subject: S7-08-20
From: John Randolph
Affiliation:

Sep. 29, 2020

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Hello, 


I wanted to comment very briefly on the proposal to raise the threshold for 13Fs. 


Institutional investors have *so* many advantages over individual investors. 13-Fs are one tool that are a huge help to individual investors; they help level the playing field, specifically with respect to resources dedicated to research. A $1 billion fund typically generates $10- $15 million in annual fees, ignoring carried interest-- $15 million buys a lot of proprietary and street research that individual investors cannot afford. A $1 billion fund -- or even a $100 million fund-- enjoys access to company management that the individual investor does not. 


A move to raise filing thresholds for 13-Fs will hurt individual investors and decrease marketplace transparency. 


Thank you, 
John Randolph 
Stanford, CA