July 14, 2020
I understand that this proposal is intended to reduce costs and burdens to smaller managers. As the Senior Analyst for a firm specializing in alternative investments including hedge funds, and one which has made it a priority to identify and invest with smaller managers (sub-$500m), we have worked with many managers at length as part of our diligence. This is an extremely important part of our diligence. I have never had a manager complain about the added burden of filing a 13F. By raising the AUM threshold to $3.5bn you are effectively putting these smaller managers at a significant disadvantage by making it more difficult for investment groups to do their diligence and get comfortable moving forward with an investment. It's already hard enough for the little guys to raise assets, while the multibuillion dollar guys see funds flow in regularly. Don't make it harder for the little guys. Further, why would the SEC choose to reduce transparency? It sends a bad signal and does more harm than good.