Subject: File No. S7-08-20
From: James Gardiner
Affiliation: COO TPW Investment Management

July 14, 2020

As a manager that focuses on investing in ETFs transparency is crucial. It is important to not only compare performance of mutual funds to ETFs but also very important to compare underlying holdings. Taking away the reporting requirement would take away investors abilities to do proper due diligence on their investments. At my pervious firm we ran SMAs, model delivery portfolios on TAMPs, and mutual funds. All of our investors were able to see our holdings, if this rule change goes into affect only the mutual fund holders would lose transparency.