Subject: File No. S7-08-20
From: David Giannini, Giannini
Affiliation: Private Asset Management

July 14, 2020

I object to the proposal to raise the AUM threshold for 13F reporting. This is a step back to the time of non-transparency which breeds maleficence. Furthermore, one reason behind this proposal is to save time and money for smaller firms. Compliance as a whole is costly both through time and money. However, there are many other areas of the compliance burden that could easily be reduced that would have a far greater reduction in time and money for investment firms.