Sep. 29, 2020
September 29, 2020 Ms. Vanessa A. Countryman, Esq. Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 rule-comments@sec.gov Dear Ms. Countryman: We appreciate the opportunity to comment on the Commission’s proposed rule regarding the reporting threshold for 13F reports for institutional investment managers. While we understand the intent of the proposed rule is to return its scope, in terms of the number of filers, closer to the level when the original rule was adopted in 1978, we do not believe the proposal takes current market dynamics into consideration. With the explosion of hedge funds, dynamic trading and activist investors since that time, issuers need more visibility into institutional investor activity, not less. It’s critical that we know about the activities of our institutional investors, even if they are conducted through smaller funds. Further, we believe regular communication with our investors is a best practice, and our investor relations team relies on the information provided by 13F reports to identify holders of our stock for this purpose. To maintain transparency, we believe the rule should continue to apply to institutional investors with portfolios in excess of $100 million. We also recommend the Commission consider amendments that would improve transparency, such as reducing the filing period down from its current 45-day requirement and expanding reporting requirements to include derivative positions. The need for effective shareholder engagement is clearer than ever, and this proposal would be a significant step backwards at a time when stakeholders are increasingly calling for greater transparency. We urge the Commission to reconsider this proposal. Sincerely, Caron A. Lawhorn Senior Vice President & Chief Financial Officer 15 East 5th Street, Tulsa, OK 74103 | onegas.com CONFIDENTIALITY NOTICE: The information contained in this e-mail message and any attachments may be privileged, confidential, and/or protected from disclosure and is intended only for the use of the individual or entity named. If the reader of the message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this e-mail message is prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.