Subject: File No. S7-08-20
From: Miles Putnam, CFA
Affiliation: Portfolio Manager, Provident Investment Management

July 14, 2020

This is a good idea. As an investment manager, my client portfolio is my primary work product. I believe the current requirement to publish that work product publicly harms my business by devaluing, and effectively stealing, my work product.

Reporting should be voluntary, and investors should be allowed to choose whether they are better served by a manager holding a private versus public securities portfolio. Clients who demand transparency through 13F disclosure will still be able to get it from managers who agree to provide it. This is the fair and appropriate free-market answer to a problem where investors will have different wants and needs.