July 15, 2020
Dear friends at SEC. I am sending this message in order to PREVENT Changes in the limits that institutional investors must have in order to fill and submit the Form 13F.
Currently, institutional traders with account values over $100M must report their holdings on a quarterly basis. These filings submitted on from 13F. The SEC is proposing raising the 13F threshold to $3.5B.
The SEC is proposing changing this rule because of what it sites as an administrative burden on smaller managers. To be clear, you are calling fund managers holding between $100M and $3.5B in assets under management "small."
It is MY opinion as well as many others, 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.
Events like the 2008 financial crisis resulted from a lack of transparency from banks and the effects of the crisis were devastating for many people all around the world
By sending this message, I hope I can persuade you from changing the threshold from $100M to $3.5B in assets under management. And thus rendering the transparency that all investors need.
Best Regards
Fernando Ortiz