July 15, 2020
Sirs
The SEC is proposing changing the rule that makes Financial Managers with portfolios between $100M and $3.5B small and is saying because they are small that there is an administrative burden on smaller managers.
To be clear, It is our opinion that this is not so much about administration burden or costs. It is more about accountability and transparency. We believe there should be more transparency - not less.
Thanks for your time and please keep the rule as it currently stands.
Ervis Thomas