July 15, 2020
It seems to me that this rule will most likely have the unintended effect of lowering trust and transparency, all with little to no benefit for the investment community at large - even for fund managers directly impacted. The integrity of the system relies critically on trust. Trust is often taken for granted until it suddenly disappears. Thoughtful, low-cost mechanisms add to trust. It is my view that this proposed change will decrease trust.
Fund managers with assets under management over $100mm have more than enough resources to manage the almost insignificant costs related to the quarterly filing. Even if that were debatable, a 35x increase seems excessive and arbitrary.
Respectfully,
LARH