July 14, 2020
Implementation would radically reduce transparency in the markets and thus reduce investor confidence. Investment holdings for a marked number of funds would no longer be disclosed to the public, resulting in loss of transparency and valuable insight. A purpose of Congressional Section 13(f) was 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. This rule change makes it much more difficult for the individual investor to trust the markets and more importantly trust the system.
Moreover, consider these salient points:
Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities.
1) Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are.
2) Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.
3) The justification for the rule change is highly questionable.
4) When is less transparency and less data ever a good thing for the small investor?
5) Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.
6) In the event of a significant correction the number of reporting managers would be diminished even further. The SP suffered a 56.4% decline during the 2007-2009 financial crisis. A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.