July 11, 2020
The proposed increase in the threshold of $3.5B for 13F reporting is too high an incremental jump from the current $100M. 13F filings facilitate thorough vetting of smaller managers, helping to assess a managers portfolio and whether the management invests the way it claims. Removing this valuable tool by eliminating the requirment for many more small funds will reduce the ability of the smaller investor to properly conduct due diligence. The proposed threshold increase should be significantly reduced.