Subject: File No. S7-08-20
From: Steven B Frankel
Affiliation: CFA

July 23, 2020

I have nearly 40 years experience in the institutional investment business as a sell-side analyst, dealing with professional investors of all shapes and sizes. Accurate information on who holds which stocks is an important part of a well functioning market. Investors need to be transparent and disclose their holdings, there is no regulatory burden on smaller funds from the current disclosure rules - the cost of reporting their holdings is next to nothing and other SEC rules already lead to significant technology (tracking performance, etc) and compliance costs. Failing to disclose simply allows hedge funds to hide their activity enabling them to get away with things like pumping and dumping. Market participants benefit from transparency and will be negatively impacted by the lack of it.