Subject: File No. S7-08-20
From: Annie Tuyet-Nhi Pham
Affiliation: Texas Tech

July 16, 2020

I am against this proposal as this would mean less transparency for small investors. This also reduces our ability to reduce risk. As another person has told me, "in the event of a significant 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". For the most recent quarter, this would reduce the number of funds that disclosed their holdings to the public from 5,283 to 549 or 90% of all filers. Please reconsider.