July 18, 2020
Gentlemen
I write to question the value of this proposed change. I am an individual investor who uses 13F data regularly. It helps me get sense of who owns companies, who's buying and who's selling, both long-term holders and short-term traders.
Current 13F reports particularly valuable for small-cap companies, where there is often little information available elsewhere. And many of the owners of these companies are small managers--those that would no longer be required to file under the proposed change.
The effort required to file today's 13F reports is largely a click on they keyboard and not a significant burden to money managers, even small ones. In contrast, managers often see these reports as providing useful insight into firms. Its's always good to know what others are doing, both the geniuses and the fools.
I applaud your desire to reduce excessive disclosure. But 13F information requires minimal cost and effort and helps make markets more transparent. I expect you will receive many comments along these lines, and I trust you will revise current proposal accordingly
For the future, instead of cutting back on 13F disclosure, why not move to a 30-day deadline, instead of 45? That's a change I'd be happy to support.
Regards
Paul Sturm