July 14, 2020
Raising the 13F reporting threshold to $3.5B decreases transparency and reduces both the Commissions and the publics access to information about our markets.
It is vital to our portfolio risk management to quantify a stock's aggregate concentration and liquidity risks as well as holder stress. Smaller firms cannot afford to pay stock surveillance firms for this analysis and rely on 13Fs. This will significantly reduce the small investor's ability to manage their risk.
Raising the reporting threshold to such a high number will limit small firms' access to company management. Public companies will only cater to the largest investors making the playing field unlevel and small firms less competitive.
The copycat argument is misguided. Copycats only buy after positions are purchased and sell after positions are sold. This is supportive to a 13F filers performance.
Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing, and securities.
As a small firm, the cost savings narrative is greatly overstated and is inconsistent with past analysis. Today, 13F reporting costs are immaterial and automated.