Subject: File No. S7-08-20
From: Michael Niven

July 15, 2020

This change is unnecessary. We should be pursuing further disclosure and transparency, and instead, not seeking to degrade in these measures. Less data and transparency is something a "free" market should NOT encourage

The cost savings in this proposal are heavily overstated and do not reflect past findings. $113.6 million is NOT accurate and does not compare to the previous methodology estimate ranging approximately around $31 million.

For some reason, the Commission makes a ridiculous assumption that each filing requires the same amount of work time from an attorney, a programmer, and a compliance clerk (heavily inflating the hourly cost estimate).

Imagine for a second, actually believing the nonsense number of hours indicated on the revision estimates: https://www.sec.gov/rules/proposed/2020/34-89290.pdf

Coupled with the fact that apparently, the senior programmer (if they are truly even needed) works the same number of hours as the attorney and compliance clerk.

A senior programmer is not even necessary to pull the required information, with how advanced and efficient systems are now days. I do not for a second believe the individuals responsible for writing this report actually believe this nonsense for a second, in terms of the revised requirements. Everything has been grossly exaggerated.