July 14, 2020
It is my understanding that filing of form 13F is an automated process for investment managers and it requires limited effort on their part. For the potential and/or existing investor, form 13F provides immense transparency into the recent and past investments of the investment manager.
In today's age of super-marketing, form 13F provides an objective way to verify whether the investment manager's execution is aligned with his/her investment philosophy. Similarly, form 13F also provides, ongoing evidence that the investment manager is continuing with his/her investment style as initially promised and is not swaying away from it.
Absent of this form, the existing investor would be at the mercy of the investment manager, to communicate the investments s/he is making. It could be too late before the investor recognizes that the investment manager has departed from his philosophy and may not be able to get out of an investment partnership or hedge fund in time to save his/her investment.
Form 13F also serves a purpose of educating budding investment managers or individual investors, about the different investment choices of more established investors.
Today the individual investor, can look at the investments of an investment manager by looking at his/her 13F form. Tomorrow, if the SEC removes the access to this tool for an individual investor and the investor makes an investment and loses, s/he may hold SEC responsible for their loss. As the individual investor was deprived of a source to validate an investment manager's philosophy and had to rely simply on the investment manager's marketing material.
I am not a legal expert, but if enough situations like the aforementioned were to happen, can it result in a class-action lawsuit filed against the SEC? You may want to think about the reputational damage, one or more such instances could do to your esteemed organization.
In my opinion, the benefits offered to investment managers are negligible, whilst the reduction of transparency is a significant and detrimental loss for individual investors.