Subject: File No. S7-08-20
From: Christopher F Poch
Affiliation: Investment Advisor

July 14, 2020

Increasing the threshold for disclosures from $100m to $300m may be appropriate but to $3b defeats the purpose of disclosures. It would be A legendary short sighted move and an obvious capitulation to the lobbying efforts of the money management business.

Please do not raise the threshold for disclosure significantly.