July 15, 2020
The proposal is frankly baffling - internationally the investment market has made vast strides toward further transparency, which this flies totally in the face of.
The suggestion that this will materially reduce costs for small firms is simply ridiculous - if filing a 13F is causing a firm significant workload, it's an indication the firm is being very poorly run. Indeed, that is my take away from reading any comments in support of this proposal - good to know who to avoid, I suppose.
It's a simple data collection exercise that anyone with a modicum of technical skill can automate entirely.
Regards