July 20, 2020
This rule would decrease transparency markedly by increasing the filing requirement so sharply from $100m to $3.5b. While we support less filing burdens on investment firms, there is no reason for such a sharp increase to the AUM threshold. A threshold such as $250m would be more than adequate.
The implications of this rule suggest less transparency for investors and the companies whose equity is being traded in the secondary markets. These are both very important for efficient markets. The opacity and inefficiencies suggested risk negatively outweighing the benefits of less filing requirements.
Thank you.