July 22, 2020
With respect, I disagree with the proposed change. Based on inflation, $100M in 1975 equates to slightly less than $500M in 2020. Therefore, I would understand raising the threshold to $500M, but not $3.5B.
I do not believe that simply adjusting the reporting limit for inflation to $500M places a significant burden on financial managers, especially given the advances in technology available to these managers in 2020 versus what existed in 1975.
More importantly, today's markets require more transparency, not less. Given the complexities of financial markets and instruments in today's world, requiring more reporting is a small price to pay for managers, while it will instill much greater confidence in all Americans who use these instruments.
In sum, I disagree with the S7-08-20 as written, and I believe that the intended benefits will be outweighed by the potential harm to average investors.