Subject: S7-08-20: WebForm Comments from cameron, ian
From: ian cameron
Affiliation: investment manager

Sep. 29, 2020

Subject: File No. S7-08-20
   From: ian cameron
   Affiliation: investment manager
   -------------------------------

   September 29, 2020

   Changing the reporting threshold for 13-F's is a bad idea. There are
   absolutely no reasons to make the change, but many reasons to keep the
   current rules.

   The SEC and other advocates for investor rights continually talk about
   the need for increased transparency and accountability for the asset
   management industry, but this policy change would significantly
   DECREASE transparency and accountability.

   I know from personal experience that the reporting requirements are
   not onerous from a time or cost perspective. The 45 day window for
   filing ensures that trading information is already stale by the time
   it is released to the public.

   It would be a contravention of the SEC's own mission, and its
   responsibility to tax payers and investors to move forward with this
   change.

   Thank you for your consideration.