July 14, 2020
Raising the reporting threshold is a thinly veiled attempt to greatly reduce accountability for smaller investment funds. Just because capital has become more concentrated doesn't mean the requirements for reporting should be made any less stringent. A large manager IS still a large manager and I think in the current world of megafunds, smaller funds should not be given a free ride. The costs associated with this filing are menial, regardless of whether they are a multi-billion dollar fund or a multi-million dollar one.