July 14, 2020
Raising the required reporting threshold from $100mn to $3.5bn for investment managers will dramatically change the landscape for investors. This means a reduction of 90% in the number of investment companies that disclose their holdings.
I deem this threshold change highly inappropriate and surprising given the SEC emphasis on transparency and protection of investors. Not to mention the meaningful gap between the previous and the new expected threshold which is even less acceptable (35x).
Thank you for your consideration and time.