Subject: File No. S7-08-20
From: Robert Baddorf, MBA
Affiliation: Management Consultant

July 15, 2020

I believe this change is a mistake as it decreases the transparency and accountability of institutional investment activities. Investors count on this information when investigating funds and having this information public is vital to maintaining honesty in the institutions and trust in the investment community. To call anything less than $3.5 BILLION in assets "small" is not reasonable.

Please reject this rule change.