July 16, 2020
Strongly disagree with these possible disclosure changes. Transparency should be a celebrated commodity and this new rollback adds an extra layer of opaqueness that wont benefit anyone. The average investor will not be able to adequately understand the risks they take in their investments. This opens the door for large amounts of corruption from managers who, now, are not obligated to disclose information, hurting investors and exposing them to fraudulent investments. Considering how this pandemic/economic slowdown has affected most people, the new number of fund managers required to disclose holdings is drastically reduce the amount of public information out there that is crucial for people. The justification seems inconsequential and very questionable. If the SEC was so concerned with adjusting for inflation, why is this not be changed every year? The need to change this seems to be motivated for alternative reasons which is more worrisome than the actual rule change. I do hope you reconsider this decision.