Subject: File No. S7-08-20
From: David Ordal
Affiliation: CEO, ExaVault Inc.

July 14, 2020

I am writing in opposition to the Form 13F reporting threshold increase in Proposed Rule S7-08-20. While I largely agree with the rest of the changes in Proposed Rule S7-08-20, the $100M reporting threshold increase will remove considerable transparency from the market, to the detriment of both 'main street' investors and academic researchers across the country.

I would encourage the SEC to remove the $100M to $3.5B increase in reporting threshold from the rule before making it final.