July 14, 2020
As a retired investor I view the 13F as a valuable research tool for managing my own portfolio. Changing the threshold to those in the proposed rule would eviscerate the value of 13F reporting. Yes, the larger funds may control a high percentage of invested capital, but following smaller funds who can be more nimble, identify smaller cap stocks beginning to break out or are selling a stock is where some of the best research is done. Again, I understand the data is delayed, and some may rely on it for the wrong reasons, but that is no reason to change something which appears to be working well.
Maybe the threshold should be moved up slightly, but please don't go anywhere near what the rule is proposing. That would be a serious mistake for an Agency whose mission is built around "full and fair disclosure".
Plus most funds are charging significant fees to their investors so they should not quibble about the costs of supplying the 13F information.
Michael T. Bierman
Dallas, Texas