July 15, 2020
This proposal would change the AUM threshold that investment managers must meet every quarter from $100 million to $3.5 billion Taking this data away will have a negative affect on transparency. Transparency is what gives investors confidence in US markets.
Given the SEC's emphasis on a level fair playing field, this rule change would hinder that effort. The reasoning behind the proposed change is the possible reduction in costs and burdens to smaller managers. Managers have been interviewed, and they routinely say that it is a highly automated process that effectively costs nothing.
Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities.
Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are.
Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't.
Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.