Subject: File No. S7-08-20
From: TOM DOWLING

July 22, 2020

Your logic is faulty.

By inflation, you should raise the threshold about four times to 400,000,000.

The size of the overall market is not a relevant factor.

Your supposed to be protecting investors via more transparency, not less.

Your regulatory requirements on very small money managers is onerous. But reporting holdings once a quarter is not a big deal. It's very easy to do.