July 15, 2020
To SEC Commissioners,
Please vote down this proposal. For the following reasons:
1. SEC will hurt not only small, but ALL investors
2. Invite fraudulent activity
3. Hurt market research
4. The cost of monitoring market exposures will increase, especially for the small investors
5. Firms that manage in excess of $100MM, already have compliance officers and procedures in place to submit holdings report 4 times a year. The cost is very negligible.
As for the privacy of research information, the data that managers provide is 45 days old and does not include non-equity positions.
It is my view that SEC is subject to lobbying efforts by fund industry and politicians. In fact, in August 2018 Trump administration had asked SEC to study abolishing quarterly earnings reports and SEC Chairman Jay Clayton (who was appointed by President Trump) said the agency continues to study reporting requirements.
SEC should be a champion of small investors and mandate that all fund managers comply with 13F filling rule and lower the reporting threshold.
Please vote down this proposal.
Arnold Rozenvasser
Individual Investor
7/15/2020