Subject: File No. S7-08-20
From: Fernando Saquelares
Affiliation: Industrial Engineer / Management Consultant

July 15, 2020

This rule is an abuse on the small, retail and average investors. It encourages less transparency by big or institutional funds in their intertwined interests, which the average investor uses as a data point to make wise investments. For example, a stock that has a high ratio of ownership by large funds may be a risky investment to the average Joe because the large fund may decide to dump their stake on any given day, based on insider information or other knowledge aside from fundamental data and news available to the public. In contrast, when there a stock has a low proportion of large fund institutional ownership, the average Joe may think it is a better, less manipulable stock investment and subject to a decentralized action that is not subject to the whims of a few big fish owning most of the stock.

It is disgusting and appalling that the SEC is considering less transparency for large funds in times when people distrust the banks, the gap between ultra rich and medium class americans.

Data shows that if the AUM threshold is raised from $100M to #3.5B per quarter, out of around 5000 funds currently required to disclose their holdings to the public, only 549 would only be left. This amount of obscurity provides a windows for corruption, manipulation of the markets and makes it harder for investors to identify risk in their investments.

The average citizen has a right to invest their own money without the need to rely on a large pension fund or retirement fund management firm because these firms may have information that should be available to the public.

This ruling needs to be stopped and be left as is, or, in the name of further transparency, the threshold should be decreased to $50M per quarter, instead of the current AUM of $100M. This ruling represents corruptive steps backwards in our system when transparency is needed most.