July 14, 2020
This proposed change would reduce the number of 13-F filers by approximately 90%, and dramatically impair access to material holdings data for millions of ordinary investors to help several thousand funds. The burden of filing a 13-F quarterly is insignificant relative to the value of the information to the public at large – according to the SECs own statement, the compliance costs could range from $15K to $30K annually per manager. We strongly oppose this proposed change as it is harmful to an open and informed market.