July 14, 2020
To whom it may concern:
I have recently learned about the proposed filing requirements for institutional investors, increasing from $100mm in AUM to $3.5B in AUM. This potential change has significant impact across many industries and will create unfair advantages In the market and substantially reduce the transparency. In our business, these quarterly filings are critical for determining which funds (including existing clients) might be interested in our research. With the change in this requirement, the smaller funds will be underserved and will end up losing performance to the larger managers, creating further inequality.
If the justification is to save money, given the manual process involved, than the SEC should be investing into technology to make this process more efficient.
Thank you in advance for taking my comments into consideration.
Best,
Greg Lederman