Subject: File No. S7-08-20
From: William Roberts

July 16, 2020

This proposal would change the AUM threshold that investment managers must meet every quarter from $100 million to $3.5 billion For the most recent quarter, that would reduce the number of funds that disclosed their holdings to the public from 5,283 to 549 or almost 90% of all filers. $2.3 trillion in investment holdings would no longer be disclosed to the public resulting in loss of transparency and valuable insight. When Congress first adopted Section 13(f) it did so to stimulate a higher degree of confidence among all investors in the integrity of the US securities markets. Taking this data away will have the opposite effect. Transparency is what gives investors confidence in US markets.

I stand with SEC commissioner, Allison Heren Lee, who has already voiced her opposition to this proposal. The proposed rule change would be a loss for all of us - it would enable more corruption and opaqueness.

The SEC should be pushing for more disclosure and transparency and not rolling back existing rules. This can only hurt small trades/investors and provides little to no benefit or savings.