Sep. 29, 2020
I'm writing as an individual investor who believes your proposal to increase the AUM threshhold from $100MM to $3.5 Billion is inimical to your avowed regulatory desire to enhance transparency in the marketplace. 1. The current minimum for 13F reporting provides a forum to discover "baby Beluga" managers whose forte is small and mid cap companies. Your 35 x suggested AUM requirement eviscerates all but the largest managers. 2. This rule would further handicap individual investors choice and limit the discovery of new managers as the older larger ones retire. 3. One of your own SEC Commissioners has written extensively about the detrimental impact your proposed rule could have on the market place so I won't repeat her persuasive arguments here. 4. Any costs required can be addressed with a miniscule fee increase for the illuminating opportunity currently available. It is completely arbitrary for the SEC to assert $3.5billion is the new minimum management asset hurdle without commenting on individual investors who peruse all the 13F filings above $100million. 5. Removing the smaller asset managers from the 13F filing obligation implies the SEC is only concerned with mega managers so the obliteration of value identification available to elicit smaller managers is negated. Thank you in advance for considering my opinion on S7-08-20. Alexander Bierce