July 14, 2020
I would urge the SEC to consider a broad array of capital markets academic studies that shows greater transparency is better for governance. Look no further than Honigsberg (2019 Hedge Fund Regulation and Fund Governance: Evidence on the Effects of Mandatory Disclosure Rules, Journal of Accounting Research 57 (4): 845-888), who finds increased disclosure regs for hedge funds leads to better fund governance. If anything, 13F filing is a straightforward process and should be an automated process. Thus, the literature would suggest that sophisticated investors (professional money managers) should report their holdings publicly at an even higher frequency. In sum, I am against the proposal, and would be disappointed to see the SEC take this proposed action.