July 14, 2020
It is totally inappropriate to raise the threshold to 3.5 BILLION.
13H and other such filings vastly and positively impact investor confidence. Raising it to such a high number will erode investor confidence.
The costs are, of course, a factor.
Considering the above here the suggestions:
1. Improve the process efficiency and reduce the costs of 13H filing.
2. Do NOT increase the threshold required for 13H filing. (at this time)
3. When the costs have been reduced, REDUCE the threshold for 13H filing to 50 million.
Thank you.