Sep. 29, 2020
I am emailing to oppose the SEC's latest 13F proposal increasing the minimum AUM filing requirement to $3.5bn, primarily because it limits the ability to conduct historic academic research on successful fund managers for the quantitative finance field. Additionally - 13F filing costs are negligible, anyone running $100m+ does not mind paying $15k per year in filing. The quote "indirect costs faced by smaller managers, such as those associated with potential front-running." is really not true given that 13Fs are filed with the SEC 45 days after quarter-end... Anyone who invests professionally knows that you need to be in stocks BEFORE they come out in the 13Fs anyways. Thank you for your consideration, Ryan