July 16, 2020
SEC Commissioners,
I am writing to oppose the amendment the reporting rules (S7-08-20) which would increase the reporting threshold under Section 13(f) from $100 million to $3.5 billion.
Although the stated reason for the proposed change is that at the time the current reporting threshold was put into place, it was meant to apply only to managers of the highest-valued portfolios, I believe the rule has, by remaining static, provided transparency, which is essential to the functioning of our system and to protect individual investors.
Thank you,
Michael Rebinski