Subject: File No. S7-08-20
From: Thomas Lucy
Affiliation: Founder + CIO: F T Lucy Co - family office

July 14, 2020

Many investment managers are well known to talk among themselves, sharing ideas and information. They also have direct access to company management that other investors do not. Given the SEC's emphasis on a fair and level playing field, this rule change makes no sense. The justification for the rule change is highly questionable - the data submission system is simple to operate and proportionately cost effective.