July 14, 2020
Dear SEC,
Raising the reporting threshold to such a high number creates immense market intransparency.
1. A market slow down like some months ago or during financial crisis would lead to a point where nearly 100% of all funds are not required to report anymore. So a 13F would become useless.
2. Retail investors suffer most due to intransparent trading activities from funds. Large stakeholder (like funds) still have an information advantage, which even becomes bigger.
3. Public companies do not fully see their shareholder basis.
4. Academic research (smaller sample size) on funds becomes very difficult/impossible.
My advice: If you have the urge to change something. Increase threshold to 200m-300m and not such a ridiculous high figure. Bear in mind, a 100m fund has easily 10 employees and roughly 1-2 responsible for reporting. Your mentioned "relief of smaller managers" in not noticable. Its even a standardized process which they will do anyway for internal reporting. Hope you will understand.
Best wishes,
Matthias Bolowski