July 21, 2020
1) The justification for the rule change is highly questionable.
2) When is less transparency and less data ever a good thing for the small investor
3) 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.
Please bring greater transparency, not less