July 16, 2020
This rule change has no basis nor justification in promoting transparency from institutional investors in fact, it purports to do the opposite. Altering the disclosure threshold will prevent small investors from being able to mitigate their investment risk as effectively due to a lack of knowledge if a stock is over-owned. Generally speaking, enacting this rule will reduce transparency and lessen insight smaller investors will have when making investment decisions. Ultimately, the only acceptable change to the Reporting Threshold would be to lower this threshold further, not elevate the threshold - which any reasonable person could perceive as a slight to the small-time investor.