July 14, 2020
I do not believe reducing transparency in the markets aligns with the SEC's stated mission. In fact, it is diametrically opposed to it.
-protect investors - publicly available holdings information for institutional investors is a valuable data source for investors. Reducing data sources available to them is certainly not in their best interest, even if netting off the reduced financial burden of this particular reporting requirement.
-maintain fair, orderly, and efficient markets - increased publicly available market data makes for a more efficient markets.
Should 13f data no long be reported, private alternative data sources will take their place. These products tend to be prohibitively expensive and available only to institutional investors which puts the public/retail investors at a disadvantage.
-Facilitate capital formation - public knowledge of stakeholders is an important dynamic in fostering capital formation, particularly among smaller companies or those with lower float whose share prices can be more readily manipulated by large investors.