July 14, 2020
This proposal would change the AUM threshold that investment managers must meet every quarter from $100 million to $3.5 billion To put it in perspective, for the most recent quarter, that would reduce the number of funds that disclosed their holdings to the public from 5,283 to 549 or almost 90% of all filers. $2.3 trillion in investment holdings would no longer be disclosed to the public resulting in loss of transparency and valuable insight. When Congress first adopted Section 13(f) it did so to stimulate a higher degree of confidence among all investors in the integrity of the US securities markets. Taking this data away will have the opposite effect. Transparency is what gives investors confidence in US markets.
Given the SEC's emphasis on a level fair playing field, this rule change makes no sense. The reasoning behind the proposed change is the possible reduction in costs and burdens to smaller managers. This justification is nonsense. I have asked several managers that file and they say it is a highly automated process that effectively costs nothing. The claimed cost savings are completely inaccurate.