July 15, 2020
Lowering the reporting threshold for institutional investment managers would be a loss for the main street investor. The SEC should be pushing for more disclosure and transparency. Not rolling back existing rules. When is less transparency and less data ever a good thing for the small investor?
Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.
In addition, raising the reporting threshold to $3.5 billion will severely limit future academic research on markets, investing and securities, and reduce public companies' opportunity to know their shareholders.
This proposed rule change can only hurt small investors and provides little to no benefit or savings.