Subject: File No. S7-08-20
From: Matthew Sargent
Affiliation: Investor

July 14, 2020

Increasing the minimum threshold will decrease transparency and trust in pooled investments such as hedge funds. Investors should be able to see what the funds they are considering are holding and for how long (at least on the long-side).

There is also great value to the individual investor of reviewing 13-f's. Being able to see what a manager you admire is doing may be a key process in someone's investment process - I don't see how increasing the minimum threshold helps the little guy.

I imagine many people will claim that filing 13-f's increases costs for smaller funds, making it more difficult for them to compete. I find this appeal hard to believe as filing 13-fs is highly automated - it's not like the funds have to go through the same rigorous reporting that a public company goes though.