Subject: S7-08-20: WebForm Comments from Gallo, Christiano
From: Christiano Gallo
Affiliation:

Sep. 29, 2020

Subject: File No. S7-08-20
   From: Christiano Gallo
   --------------------------

   September 29, 2020

   There are quite a few reasons why the reporting threshold should not
   be changed:

   - 13F filing costs for managers are negligible
   - It's hard to front-run someone 6 weeks later
   - It will become harder to understand what smaller managers are doing
   - Drastically reduces transparency and limits future academic research
   - Investors and companies won't know the shareholder base
   - Proposal goes against original 13F goals SEC's own mission to
   protect investors maintain fair, orderly, and efficient markets and
   facilitate capital formation.

   In short, the negatives far outweigh the positives.