July 16, 2020
One of the reasons outlined in the proposal is that "smaller" managers closer to the $100 million mark have costs of around $35k associated with their 13F filing. One of the points in the proposal was that this rule would save those managers that $35k fee and save just over $100 mill per year in total. That's $100 mill saved on managers that collectively hold half a trillion dollars. I firmly believe that the manager who is responsible for $100 million dollars can afford a $35k annual fee to publicly disclose information, and should publicly disclose this information for the good of every investor managing under $100 million.