July 14, 2020
I am a 30 year old, individual value investor that invests my own money in a small portfolio. For years, I have used 13F filings as one of many information gathering tools to help inform my investment decisions. I strongly I disagree with the decision to move up the reporting threshold to $3.5B because I believe it will harm small investors like myself. You are eliminating a small, but important, piece of information that helps all investors (especially small ones) make educated decisions and instead making the market more opaque and similar to European equity markets. To reiterate, the decision will harm small investors by leaving them without vital information to make educated investing decisions. If you are going to raise the minimum threshold, $250-$500M would make more sense in my opinion.
In addition, having worked for many years in the hedge fund industry, I believe that the benefits of the savings to hedge fund organizations (or more broadly investment organizations) is very much exaggerated. In truth, this amount of money they will save is likely immaterial to the organizations compared with the (unnecessary) service/value you are providing by hiding their positions to outside investors. What they really want is to be able to disclose less, and hide their positions. I think the current standard (quarterly, 45 day lag) is sufficient in providing the necessary information without leaking any of the key elements of investment organizations' investment process.
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