July 18, 2020
I strongly disagree with the proposed change in the reporting threshold for institutional investors for the following reasons:
- Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities.
- Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are.
- Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.
- The justification for the rule change is highly questionable.
- When is less transparency and less data ever a good thing for the small investor?
- Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.
- In the event of a significant correction the number of reporting managers would be diminished even further. The SP suffered a 56.4% decline during the 2007-2009 financial crisis. A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.
Thank you