July 16, 2020
I am strongly opposed to the proposed change, which would eliminate nearly 90 percent of all 13-F filings for the following reasons:
1. It will substantially reduce transparency. We need more transparency from all financial companies involved with the public, not less.
2. One obvious reason is that the proposal, if implemented, is an open invitation for managers to run Ponzi schemes, because there would be no check available to the public whether they are truthfully reporting their investment returns, or just making them up.
3. The 13F filing cost is miniscule for managers with all the data readily available in IT systems. I find the SEC's concern about filing costs rather disingenuous. The SEC estimates filing costs of $15,000 to $30,000 per year for a hedge fund which is the equivalent of about $0.30 for a person with a moderate income.
4. It will not benefit the hedge funds either because investors will shun those funds for lack of disclosure reasons.
5. I was under the impression that the SEC is chartered to make investing a level playing field for all investors. This proposal shows that the SEC does not take this mandate seriously.