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.