Subject: File No. S7-08-20
From: Tim Hatamian, Ph.D.
Affiliation: Mathematicus Laboratories

July 15, 2020

This rule change is a terrible idea. Having been a consultant to several large and medium funds I can tell you that it is tantamount to insider-ish trading. Why? because Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.