July 14, 2020
I am very disappointed that the SEC is moving in the opposite direction of "transparency" and "leveling the playing field" by reducing disclosure requirements of large funds. As a fundamental investor, gaining the limited exposure to the behavior of key investors is a small factor but an important one in my investment decisions. I hate to see an increase in secrecy which is what this change will entail rather than greater transparency which the law originally was intended to provide.
Please do not raise the investment threshold for disclosing 13(f) reports. The rules are good as they stand, and the cost to administer th reporting is negligible for all concerned and hardly a legitimate reason for the change.
Howard