July 15, 2020
Greenhaven Associates is a registered investment advisor with about $6 billion under management. We know that other advisors and individuals read our 13F filings and we fear (although we cannot prove) that others sometimes purchase or sell stocks based on our filings. To the extent that such purchases and sales by others affect the price of shares that we wish to purchase or sell more of, our 13F filings will cost our clients money - and therefore are not in the best interest of our clients. To mitigate this problem, we suggest that the threshold for 13F filings be materially larger than the proposed $3.5 billion, or that the filings be required once per year instead of four times per year, or that the required filing date be 90 or so days after quarter end. Thank you for your consideration.