July 14, 2020
I strongly object to proposed change in reporting threshold for Form 13F. The reasons citied for making this change completely ignore the needs of investors looking for verifiable information on investment managers in which they are considering investing. Doing due diligence on smaller managers is particularly important and checking 13F filings is a valuable tool in this process. Increasing the threshold might even hamper competition because smaller managers will face marketing challenges and additional costs to provide verifiable data to potential clients.
I reject the contention that front running is even possible, given the delay in publishing the data. There is also no proof that copycatting of portfolios has any impact on prices or costs. If anything, this practice would benefit the holdings of these managers by providing additional buying pressure. Products based on mimicking portfolios already screen for size of managers and thus should not impact smaller managers.
In conclusion, the current 13F filing requirements provide valuable information to the investing public and should be maintained at the current threshold.