July 17, 2020
The proposal to increase the filing threshold substantially reduces critical market transparency and likely damages both the small investor and the advisors that serve them. Our firm and its management strongly oppose any reduction in market transparency, especially those that may adversely affect our clients, as we believe this would.
There is not a substantial cost to filers, nor when passed through to underlying investors. The threshold should remain the same and does not pose a burden upon filers or investors.
It is our belief that the potential harm in reducing market transparency far outweighs any potential savings, in a magnitude that makes this proposed change disastrous to confidence in market structure and fair access to information for all investors. We believe that retaining the current filing threshold fulfills a greater fiduciary duty to all market participants.