July 14, 2020
I am very disappointed to learn of this proposed rule change.
If approved then this change will reduce the number of funds that disclose their holdings to the public from 5,283 to 549.
$2.3 trillion in investment holdings would no longer be disclosed to the public resulting in loss of transparency and valuable insight.
When Congress first adopted Section 13(f) it did so to stimulate a higher degree of confidence among all investors in the integrity of the US securities markets. Taking this data away will have the opposite effect.
The reasoning given for the proposed change is the possible reduction in costs and burdens to smaller managers. Yet many managers say it is a highly automated process that effectively costs nothing.
This can only hurt retail investors and as a foreign investor in US markets it will, if passed, severely damage my confidence in the US as an investment sector.