July 10, 2020
On behalf of the B. Riley family of regulated entities, we wholeheartedly endorse raising the threshold for reporting 13-f holdings.
The administrative and compliance costs associated with such filings place an undue burden on small firms while arguably providing little in the way of usable investor data.
Further, we would endorse pegging the 13-F filing threshold to the average rate of return earned by the markets annually, inclusive of dividends and rounded to the nearest $100M, during the 45 years that the rule has been in existence.
Finally, we would endorse eliminating the omission threshold for reporting purposes. While we agree that these small positions provide little in the way informational value, having the option to remove them adds an extra layer of analysis and review that increases the regulatory burden.
Thank you,
Michael Markunas
Chief Compliance Officer
B. Riley FBR, Inc.
B. Riley Wealth Management, Inc.
B. Riley Capital Management, Inc.