July 14, 2020
I am opposed to the reduction in reporting requirements. It would make most of this reporting almost meaningless.
While I am in favor of reducing regulations, there are some regulations that are needed. Those that fall in the area of transparency and providing useful public information would fall into that category. This regulation serves that purpose.
Worst of all, raising the threshold for these reporting requirements would deprive virtually all retail investors and corporations of critical investment information. How is a current $100 million reporting requirement too low? With that level of investment, the reporting costs are not that significant.
Investment funds, mutual funds, and others subject to this reporting, are part of a "tribe" who share common circles and speak to each other regularly. They share information among themselves and this regulation would do nothing to change that. As a result, by allowing this information to be "hidden" simply deprives the public, especially retail investors, of key information on making investment decisions. However, it allows a high level of secrecy to the benefit of those who would no longer subject to this transparency.
One other consideration is that this information is used for academic research, analysis, and education. Eliminating it from the public view stifles the associated financial education.
For these reasons and many more I am opposed to this proposed change. The current $100 million dollar threshold is not too granular and the reporting requirements are not onerous.