Subject: S7-08-20
From: Andy Grossman
Affiliation: EVP, Capital Markets & Investor Relations

Sep. 29, 2020

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To Whom it May Concern, 

I’m writing to voice my opposition to the new SEC 13F proposal for the following reasons:

The cost for the institutional investment community to file their 13Fs is negligible 
It is all historical information, therefore difficult to front-run 
Investor transparency is important for allocators of capital into funds. 13F’s give detail that many funds are not willing to share with their investors 
Companies won’t know their own shareholder base 


Thank you for considering these reasons why I oppose the new proposed rules around 13Fs. 



Best,



Andy Grossman







Andy Grossman 
EVP, Capital Markets & Investor Relations

325 W Huron St. 
No. 412 | Chicago, IL 60654
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