July 16, 2020
The justification for the rule change is highly questionable. When is less transparency and less data ever a good thing for investors. 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. In the event of a significant market correction the number of reporting managers would be diminished even further. The SP suffered a 56.4% decline during the 2007-2009 financial crisis. A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.