Sep. 30, 2020
To Whom It May Concern: As a 30-year old veteran of the industry, I have experience as an analyst, portfolio manager as well as Chief Compliance Officer. I feel strongly that the proposal to increase the minimum AUM to be required to file form 13F would reduce market transparency and harm investors. My reasons are as follows: Filing costs to managers are negligible and in my experience much lower than those described in the proposal; “Front-running” based on 13F filings is largely a non-issue as the information is 45-days old at best, which leaves enough time to all but the biggest managers to complete their trades; Due diligence and transparency would be dramatically reduced: 13Fs provide a very useful tool when researching and monitoring investment managers. The proposal would reduce the numbers of managers filing by about 90% according to current estimates; Companies would see much reduced information about their shareholder base, particularly smaller companies. I urge you to reconsider. Very truly yours, Jean-Luc Nouzille, CFA® Co-Founder, Managing Partner Bristlecone Value Partners, LLC 12301 Wilshire Boulevard, Suite 320