July 15, 2020
I strongly disagree with the proposed change in the reporting threshold for institutional investors for the following reasons:
1. In the event of a significant correction the number of reporting mgrs would be minimal.
2. Many mgrs are known to talk among themselves, sharing ideas and information. They have access to company mgmt that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.
3. The justification for the rule change is nonsense. I know several reporting mgrs and they say it is a trivial, highly automated process that effectively costs nothing. The claimed cost savings are made up and completely inaccurate.
4. Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing, etc.
5. Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are.
6. Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.
Thanks you