July 16, 2020
I strongly disagree with this rule change. This would reduce the number of funds that disclose their holdings to the public from 5,283 to 549 or almost 90% of all filers. That 90% reduction would lead to a loss in transparency and valuable insight of the management of $2.3 trillion in investment holdings. Yes, perhaps the number should be raised from $100M, but not to a number that leads to a reduction of 90% of filers.