July 14, 2020
The proposed change to a higher asset threshold would severely impact market transparency in a negative way and thereby undermine investor confidence. The ability to see on a delayed basis market positions of the majority of institutional managers has enabled investment consultants, institutional investors, allocators and private investors to intelligently select money managers for a diversified portfolio of managers will be severely hampered. This proposed change does not contribute to market transparency and will hardly save managers an appreciable amount of cost as the process is highly automated. I was an investment consultant for over 18 years and the ability to see historical positions from a trustworthy source helped give me and my clients confidence there was less likelihood of fraud in a managers performance returns. I urge the SEC to not pursue this proposed change.