Subject: File No. S7-08-20
From: Philip Howard, Ph.D.
Affiliation: Professor of Finance, Wake Forest University

July 14, 2020

The proposal of increasing the reporting threshold to $3.5 billion is bad for transparency, academic research and policy making. 13F data is widely used by economists to examine questions of systemic risk from institutional investors. The research produced using this data has informed policy debates and regulators. Increasing the threshold would severely hamper the ability to continue conducting academic research in this area.