Subject: File No. S7-08-20
From: Christian Rahl

July 16, 2020

This seems like a terrible move by SEC. The resulting reduction in transparency to managed funds would be significant. As it stands it would reduce it by 90%. This could have an incredible impact on small investors and possibly small funds.

If investors are worried about small funds not disclosing the 13F they may move to large funds who are required to by law. On top of that, this allows smaller funds to lie trying to sell a faulty product.

I hope this rule does not pass.