July 22, 2020
I do not think that an industry regulator should be increasing the already opaque nature of the financial industry reporting requirements. This is a form of regulatory capture where the agency is actually working for the industry its supposed to be regulating. This does not help the retail investor at all, this change helps only the hedge funds and other larger family offices. Most large hedge funds have AUM of 1 billion to 3 billion, so all the major hedge funds would be exempt from reporting If anything, the AUM requirement should be about $400 million, which accounts for inflation instead of the market growth calculation used here. I think an industry regulator should be enacting protections for the retail investor and not the other way around. This proposal should require the reporting of not only long positions, which it already does but also short positions. This would provide huge insight to where the institutional investors think the market is headed. More information provided to the market albeit delayed will create a more efficient market which is the goal. Please do not fall victim to lining your pockets and looking the other just because big money is tired of reporting their long positions. That is just silly and really irresponsible as you are a supposed steward for the retail investor. Please do not enact this rule change.