July 15, 2020
On the SEC website About What We Do, the first statement says:
"The mission of the U.S. Securities and Exchange Commission is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation."
13Fs serve as a vehicle which promotes transparency and due diligence from institutional investors. These filings are also used by individual investors and public companies to gain clarity on investment positions which are crucial to make informed decisions and keep asset allocations true to respective fund charters.
This rule is unfortunately in principle opposed to the charter listed on SEC's own website. Further, the 30x increase in AUM limits is quite drastic and has a consequence of pushing a huge majority of institutional investors in the dark. It may encourage institutional investors to reduce/fragment portfolio sizes to go dark eventually resulting in reduced transparency and efficiency of markets.
In summary, the rule is incoherent with what the SEC describes as its mission and if it has to be implemented I would suggest a more modest increase from the 100 million requirement that exists today.
Thank you for your attention.