Subject: File No. S7-08-20
From: Chance Finucane
Affiliation: CIO, Oxbow Advisors

July 14, 2020

I do not want to see the AUM threshold increased to $3.5 billion.

It's valuable for individual investors to see what a mutual fund actually owns and if that aligns with what the fund managers say their strategy is. If the investor can't see what is owned, they're selecting among black boxes without knowing what they're getting in return.

If you want to adjust the threshold for inflation, that would move it up to $500 million. That's reasonable. But $3.5 billion is too much. Please do not make such a large change to the rule.

Thanks,
Chance