July 19, 2020
The proposed reporting threshold increase from $100 million to $3.5 billion should not be implemented. The information from Form 13F helps with investor confidence and is used by market participates to make better investment decisions. Reducing the information available to the public will hurt investor confidence and will reduce the ability for small investment managers and retail investors to compete. The Purpose of the Securities Exchange Act of 1934 is to prevent inequitable and unfair practices in the markets. Increasing the threshold will create inequitable and unfair practices in the markets due to less transparency from larger institutional investment managers. Overall, the threshold increase can create direct and indirect cost savings from compliance, but the cost savings do not offset the negative effects to the public.
Regards,
Jose Ortiz